The content of policy HC1 is broadly welcomed as it encourages the principle of new and enhanced community facilities (that would include indoor sports facilities) and seeks to protect existing facilities. The policy principles are considered to broadly accord with Government policy in section 8 of the NPPF especially paragraphs 70 and 74. However, the following issues are identified with the content of the policy which should be addressed to ensure that it is consistent with Government planning policy:
* The criterion (i) relating to facilities being replaced in appropriate alternative locations does not require the replacement facility to provide equivalent or better provision in terms of quantity and quality. Paragraph 74 of the NPPF (and Sport England's planning policies) specifically advises this. Sport England has had experience of adopted policies in local plans which are similar to this which due to the lack of explicitness about the quantity and quality of replacement facility requirements have resulted in inferior alternative facilities being proposed due to developers exploiting the lack of clarity and guidance on this matter.
* In relation to sports facilities, paragraph 74 of the NPPF permits the principle of existing facilities being built on if the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss. As the section of the policy relating to the loss of facilities does not make provision for this, for consistency with the NPPF and to avoid issues arising during the implementation of the policy, an additional criterion is requested to cover this but the scope only needs to cover sports facilities.
* For consistency with paragraph 70 of the NPPF and the recommendations in the Council's Indoor Sports Facility Strategy, and to reflect the importance of community facilities being multi-functional the policy or the supporting text should explicitly support the principle of shared use facilities such as the dual use of school facilities for sport and other community uses in appropriate locations.