3. Communities

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Support

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24203

Received: 07/12/2018

Respondent: Burwash Parish Council

Representation Summary:

We are broadly in agreement with this section but do feel that the current stress on businesses could be helped by lowering business rates. This is a Government matter but should be included as a lobbying point.

Full text:

We are broadly in agreement with this section but do feel that the current stress on businesses could be helped by lowering business rates. This is a Government matter but should be included as a lobbying point.

Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24578

Received: 07/12/2018

Respondent: Sport England, South East Region

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Currently the NPPF states:

Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:

* an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements
* the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location
* the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.

I note that there would not appear to be a policy dedicated to the protection of playing fields and sport facilities in line with the NPPF. Sport England would strongly recommend that such a policy be included in line with national policy.

Full text:

Thank you for consulting Sport England on the above named document. Please find herein our formal comments for your consideration.

Sport England has an established role within the planning system which includes providing advice and guidance on all relevant areas of national, regional and local policy as well as supporting local authorities in developing the evidence base for sport.

Sport England aims to ensure positive planning for sport, enabling the right facilities to be provided in the right places, based on robust and up-to-date assessments of need for all levels of sport and all sectors of the community. To achieve this our planning objectives are to seek to PROTECT sports facilities from loss as a result of redevelopment; to ENHANCE existing facilities through improving their quality, accessibility and management; and to PROVIDE new facilities that are fit for purpose to meet demands for participation now and in the future.

We work with the planning system to achieve these aims and objectives, seeking to ensure that they are reflected in local planning policies, and applied in development management. Please see our website for more advice: http://www.sportengland.org/facilities-planning/planning-for-sport/

Site allocations and playing field provision

Development that would either involve the loss of playing field or prejudice the use of the playing field (for example, housing immediately adjacent to an existing playing field) would be strongly resisted by Sport England.

I also see that as part of site allocation BEX10 there is the potential for a cricket and or football pitch. I would advise that this element of the site allocation should be justified by a robust and up to date Playing Pitch Strategy (see below). It is often the case that single-pitch sites are found to be unsustainable and therefore there can be issues finding clubs/tenants to take them on.

I also note that BEX11 (Sidley Sports Ground) has been allocated for sport. Sport England is fully supportive of this allocation which is backed up by evidence in the most recent Playing Pitch Strategy.


Playing Pitch Strategy

The Local Plan should be informed by a robust and up to date assessment such as the Playing Pitch Strategy which I understand was completed for Rother in 2016. Sport England's most recent Guidance is clear that PPSs should be updated at least annually (Stage E). I would strongly encourage you to ensure a Stage E review is undertaken as soon as possible in order to ensure the evidence base for the local plan is up to date and robust. I note that this document forms part of the Local Plan evidence base. This document should also be used to inform questions around sporting infrastructure that is required (either in terms of updating or new provision).

Protecting playing fields and sport facilities
Currently the NPPF states:

Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:

* an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements
* the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location
* the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.

I note that there would not appear to be a policy dedicated to the protection of playing fields and sport facilities in line with the NPPF. Sport England would strongly recommend that such a policy be included in line with national policy.

Economic Development

it is noted that the local plan includes a section on the economy.

Sport England wishes to highlight the fact that sport makes a very substantial contribution to the economy and to the welfare of individuals and society. It is an important part of the national economy (measured using Gross Value Added) and employment. For those who participate there are health and well-being (or happiness) impacts. Its economic impact places it within the top 15 sectors in England and its wider economic benefits mean that it is a key part of society, which results in huge benefits to individuals and communities. Sport England would therefore request that the value of sport to the economy is reflected within the Local Plan.

I note within the document that there are references to ensuring the health and wellbeing of residents, improving pedestrian and cycle connectivity, prioritising cyclists and pedestrians (including creating links where previously there were none) and ensuring high quality public realm; these are welcomed.

Sport England believes these references would be further strengthened by specifically referencing Sport England's Active Design Guidance, with the recommendation that future design proposals follow its principles.

Sport England and Public Health England have recently refreshed our 'Active Design' guide which provides some really useful advice and case studies with clear reference to the NPPF to maximise the opportunities for design in physical activity. Sport England would commend this to you and suggest the concept of 'Active Design' be incorporated into policy and any new developments - please see website extract and link below:

Active design

We believe that being active should be an intrinsic part of everyone's daily life - and the design of where we live and work plays a vital role in keeping us active.
Good design should contribute positively to making places better for people and create environments that make the active choice the easy choice for people and communities.

That's why Sport England, in partnership with Public Health England, has produced the Active Design Guidance. This guidance builds on the original Active Design (2007) objectives of improving accessibility, enhancing amenity and increasing awareness, and sets out the Ten Principles of Active Design.

I note within the document that there are references to ensuring the health and wellbeing of residents, improving pedestrian and cycle connectivity, prioritising cyclists and pedestrians (including creating links where previously there were none) and ensuring high quality public realm; these are welcomed.

Sport England believes these references would be further strengthened by specifically referencing Sport England's Active Design Guidance, with the recommendation that future design proposals follow its principles.

Sport England and Public Health England have recently refreshed our 'Active Design' guide which provides some really useful advice and case studies with clear reference to the NPPF to maximise the opportunities for design in physical activity. Sport England would commend this to you and suggest the concept of 'Active Design' be incorporated into policy and any new developments - please see website extract and link below:

Active design

We believe that being active should be an intrinsic part of everyone's daily life - and the design of where we live and work plays a vital role in keeping us active.
Good design should contribute positively to making places better for people and create environments that make the active choice the easy choice for people and communities.

That's why Sport England, in partnership with Public Health England, has produced the Active Design Guidance. This guidance builds on the original Active Design (2007) objectives of improving accessibility, enhancing amenity and increasing awareness, and sets out the Ten Principles of Active Design.

Ten principles

The ten principles have been developed to inspire and inform the layout of cities, towns, villages, neighbourhoods, buildings, streets and open spaces, to promote sport and active lifestyles.

The guide features an innovative set of guidelines to get more people moving through suitable design and layout. It includes a series of case studies setting out practical real-life examples of the principles in action to encourage planners, urban designers, developers and health professionals to create the right environment to help people get more active, more often.

The Active Design Principles are aimed at contributing towards the Government's desire for the planning system to promote healthy communities through good urban design.

Active Design has been produced in partnership with David Lock Associates, specialists in town planning and urban design.

Thank you once again for consulting Sport England. Please do not hesitate to contact me should you have any queries.