Comment

Draft Development Contributions SPD - September 2022

Representation ID: 10260

Received: 10/11/2022

Respondent: Sport England - East Region

Representation Summary:

Support is offered in broad terms for the approach to providing for outdoor sport in new development set out in section 8.4 especially the use of the Council's Playing Pitch Strategy & Action Plan to inform provision and Sport England's Playing Pitch Calculator to calculate demand. However, comments are made in relation to the continued reference to the use of the Fields in Trust standards for application to playing pitches/other outdoor sport, the need to update the Playing Pitch Strategy & Action Plan to use the Playing Pitch Calculator and the accuracy of paragraph 8.4.6.

Full text:

Outdoor Sports Facilities
Support is offered for reference being made to the Council updating its Playing Pitch Strategy & Action Plan 2018 and this being used to inform new playing pitch provision as the Council’s most up-to-date evidence base for outdoor sport should be used for informing provision that will be made by new development. This would accord with Government policy in paragraph 98 of the NPPF.
The reference in paragraph 8.4.20 to the use of Sport England’s Playing Pitch Calculator for estimating the demand that will be generated from new development is welcomed as this would provide a robust tool for estimating demand if used in conjunction with the Playing Pitch Strategy & Action Plan.
However, I would make the following comments:
• The use of the Fields in Trust standards for playing pitches and other outdoor sports is not consistent with the Council’s Playing Pitch Strategy & Action Plan’s guidance which does not advocate the use of these standards. This should be considered as developers may be confused about whether they need to follow the advice in the Playing Pitch Strategy & Action Plan’s as advocated in paragraph 8.4.6 or apply the standards as advocated in paragraph 8.4.7. The removal of playing pitches and other outdoor sports from the open space standards section would address this.
• While the use of Sport England’s Playing Pitch Calculator is welcomed, the team data used in the calculator derives from the 2018 Playing Pitch Strategy which is now out of date. Furthermore, applicants do not have access to the calculator. It will therefore be important that the Council reviews its Playing Pitch Strategy as soon as possible to ensure that the most up-to-date team data is used plus familiarises itself with how to use the calculator so that advice on the calculator outputs can be provided to developers. Sport England would be willing to provide advice and support to the Council in this regard.
• For accuracy, in paragraph 8.4.6, reference should be made to the Playing Pitch Strategy & Action Plan setting out outdoor sport needs across the district and will be used to inform new outdoor sports facility provision. This is requested to recognise that the scope of the Playing Pitch Strategy extends beyond playing pitches to cover all of the principal outdoor sports;