While the intentions of this policy are welcomed, there are concerns about its detail in relation to according with the Council's evidence base for outdoor sport and meeting Government policy in the NPPF. In particular:

* The policy does not specifically support the principle of new outdoor sports facilities in suitable locations as the policy (criterion (a)) focuses on open space within new residential developments. In practice, developments will come forward for new outdoor sports facilities such as new or enhanced playing fields on the edge of urban areas or in the countryside and it is important that a positive policy approach is taken to help community sports facility needs (as identified in the Council's Playing Pitch Strategy) to be met as proposals for such facilities can sometimes conflict with other planning policies and a clear policy approach is therefore considered necessary. A positive approach to new outdoor sport/open space would also allow the policy to accord with paragraph 70 of the NPPF.
* In relation to outdoor sports facilities, it is unclear what the approach to provision in new development will be as the Council's evidence base (Playing Pitch Strategy) did not recommend standards for this type of open space provision. Furthermore, with the exception of some of the strategic allocations, it will not be justifiable or appropriate for most residential developments to make on-site outdoor sports provision. Clarity is therefore needed on the approach to outdoor sport especially as the policy advises that exceptions to criterion (a) will only be made in exceptional circumstances. For outdoor sport, in practice it will be the exception for developments to make on-site provision so it is considered that this approach is too generic for applying to all open space types. It is considered that financial contributions towards delivery of projects identified by the Council in the playing pitch strategy would be the most appropriate solution unless direct on-site provision is required as set out in master plans for the strategic allocations.
* The reference in the supporting text implies that developments of less than 200 dwellings will generally not be required to make any open space provision. This is of concern given that the majority of new residential developments will be less than 200 dwellings in scale and collectively these developments will create significant additional demand for open space including outdoor sports facilities. Unless such development makes additional provision for meeting the needs that it generates, there is a concerns that pressure will be placed on existing facilities which may not be accessible or have the capacity for meeting these needs. While it would not be appropriate for smaller developments to make on-site provision they should be required to make financial contributions as the evidence base has identified needs for new or enhanced provision to meet future needs which is not linked to the scale of residential developments. A reference to the need for all new residential developments to make provision for open space including outdoor sport is considered to be justified therefore