Solihull Local Plan (Draft Submission) 2020

Provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy P14 sets out how developments which will cause or be subject to existing
noise, odour or atmospheric pollution, will need to satisfactorily mitigate or abate the identified negative impact on amenity.
The Policy in part covers NPPF paragraph 182 agent of change principle. However, it fails to consider circumstances such as a developments adjacent playing field site for example a cricket club, which could be at risk of ball strike. In such circumstances, in line with NPPF paragraph 182, the development would need to provide mitigation through the provision of ball stop netting to ensure the use of the playing field is not prejudiced or that any unreasonable restrictions are placed on the use of the site.
An additional criterion should be added to Policy P14 to ensure consistency with national planning policy paragraph 182.
* Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed.

Policy P15 could be made more effective in promoting health and well-being, in line with NPPF paragraph 127, by referring to Sport England’s Active Design Guid-ance. The Guidance sets out 10 principles which developments should seek to ad-here to promote activity, health and stronger communities through design.
Active Design is supported by Public Health England and is part of our collabora-tive action to promote the principles set out in Public Health England’s ‘Everybody Active, Every Day’, to create active environments that make physical activity the easiest and most practical option in everyday life.
Add reference to point Policy P15 point 4 to help achieve Objectives F, H and J -
4. All developments should comply with the urban design principles set out in es-tablished current design guidance, including at present; The National Design Guide (2019), Urban Design Compendium 1 and 2 (2007), Manual for Streets 1 (2007) and 2 (2010), Active Design (20015), Building for Life 12 and Secured by Design principles, or their equivalents.

Sport England are supportive of Policy P18 Health and Wellbeing with it containing a number of Active Design Principles which help to promote physical activity.
Sport England considers the policy could be made more effective through the promotion of co-location (the grouping of destinations such as community facilities, schools, shops, work places, sports facilities and leisure centres within close proximity of each other), allowing users to make only one linked trip to an area for multiple reasons. Co-location assists with linked trips reducing the need to travel and allow more time for people to linger and be socially interactive, whilst also creating variety and vitality in town and local centres.
Linked to the above supporting infrastructure should also be promoted such as public conveniences; drinking fountains; cycle, mobility scooter and pushchair storage; changing rooms; quality of seating; Wi-Fi access; shelter and showers. The above are all elements that can influence physical activity choices and should be provided where appropriate to meet the needs of a range of potential users.
Supporting infrastructure to enable sport and physical activity to take place should be provided across all contexts including workplaces, sports facilities and public space, to facilitate all forms of activity.
Provision of new public open space, children’s play, sports and recreational facilities
Point 7 sets out new housing development will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, in line with the minimum standard of 3.57ha per 1,000 population.
The Council’s Playing Pitch Strategy Update and Playing Pitch Mitigation utilises Sport England’s Playing Pitch Demand Calculator Tool to ascertain the playing pitch demand from proposed housing allocations contained within the Plan.
Sport England promotes the use of the calculator with it being informed by a local evidence base document assessment of supply and demand. It is unclear if the standard of 3.57ha per 1,000 population encapsulates playing field provision and if so, how has the figure been justified to identify demand in line with Playing Pitch Strategy and whether it would meet the CIL regulation 122 tests.
Provision of new public open space, children’s play, sports and recreational facilities
Point 9 states new housing developments will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated. It is unclear why the viability caveat is included particularly given Policy P21 and the Plan’s objectives F and J, it might be the circumstances that other contributions should not be sought or that contributions should be proportionality reduced.
Indoor Sports Facilities Strategy 2012

Policy P20 points 10 and 13 refers to an Indoor Sports Facilities Strategy 2012. The document sets out provision standards based on deficit and surpluses for the Borough and then applies these standards to the 2026 projected future population of the Borough. Therefore, the standards proposed and identified deficits/surpluses are not based on robust and up to date assessment of need as there is a failure to consider needs up to 2036.
On the basis of the above the policy (and the IDP) is not consistent with national planning policy with NPPF paragraph 96, which requires planning policies to be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision.
Playing Pitch Strategy
Sport England welcomes the authority undertaking a monitoring and review of its Playing Pitch Strategy 2017. The Playing Pitch Strategy (update) 2019 provides an update on the following inputs amongst others; sites (where informed by national governing bodies and the LPA); team numbers (informed by national governing bodies); strategy period (extending from 2026 to 2036); and site actions.
The update document reaffirms that there are current and future shortfalls in playing field provision within the Borough. Therefore, to ensure demand for pitches are met there is a need to protect existing sites; provide new sites and to improve the quality of the existing sites where identified within the Playing Pitch Strategy Action Plan. The document also provides a robust evidence base to inform the Playing Pitch Mitigation Strategy which establishes the need to replace existing playing field sites proposed for development and identify the playing pitch demands from residential developments. The use of the Playing Pitch Strategy Mitigation report within the site allocations policies contained within the Plan is welcomed and in line with NPPF paragraph 96.
It should be noted dialogue with the LPA as part of the PPS update work confirmed that the authority will conduct a full Playing Pitch Strategy in early 2022, this is supported by Sport England to ensure that authority evidence base remains robust. It should be noted that the authority should still undertake annual reviews in line with Stage E of Sport England’s Playing Pitch Strategy Guidance.
1. The incorporation of the below text within P20 ensures that the demand for playing pitches will be informed/justified by evidence namely the Council’s Playing Pitch Strategy in line with NPPF paragraph 96.
Developer contributions will be required to enhance provision of playing pitch-es, based on additional demand generated by the new residential development and the sufficiency of existing provision to meet current and projected need. The Council will have regard to Sport England’s strategic planning tools and findings of the Playing Pitch Strategy to determine an appropriate amount and type of contribution or provision within new developments.
Where it is agreed by the Council that on-site pitch provision is appropriate to meet identified demand, the applicant is required to provide the new pitch(es) and make provision for its management and maintenance in perpetuity, and clarify these arrangements within a management plan to be agreed by the Council.
2. To ensure that the policy is effective in achieving its objective and policies considerations are not replicated the following amendment is suggested:
New housing developments will be required to provide or contribute to-wards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated.
3. Indoor Sports Facilities Strategy 2012
The authority should commit to updating its Indoor Sports Facilities Strategy 2012 with works commencing prior to the adoption of the Plan to ensure the Plan is consistent with NPPF paragraph 96.

Policy BC2 2. V states the retention of the existing playing field site which is welcomed and in line with the finding of the Playing Pitch Strategy. However, SMBC illustrative concept masterplan appears to display a road abutting the playing field site and the removal of part of a hedgerow which creates a boundary for the playing field site. It is unclear why this has been proposed as it could lead impact on the use of the site such as it being less secure and balls leaving the playing field site.
To ensure that there is reduced impact on the use of playing field the concept masterplan should maintain a strong boundary for the playing field site.
Sport England welcomes the vast majority of the proposed housing allocation policies identifying a need to provide a financial contribution towards the provision of new playing pitches and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy and the Playing Pitch Strategy which identified that there are current and future shortfalls in pitch provision.
However, at this point in time it is unclear as to where the contributions will be directed to with the Plan failing to identify the location or allocation of the new playing pitches/hubs sites.
Further to this on the larger proposed allocation sites (sites which generate the demand for multiple pitches) the illustrative concept masterplans fail to incorporate any on-site playing pitch provision As such there is a possibility that no additional pitches are created which could lead to the deterioration of existing pitches (which already in short supply) due to their use being exacerbated even further.
It should also be noted that ancillary uses such as car parking and changing room facilities will also be required to support the use of playing field sites for formal activities in line with the Playing Pitch Strategy.
Pitch Provision
To ensure the shortfalls identified within the Playing Pitch Strategy is met in accordance with NPPF paragraph 96 the Concept Illustrative Masterplans for sites which create the demand for multi playing pitches should clearly display locations for the pitches and ancillary provision. The need to provide for the pitches will rescind upon such time suitable new off site playing field site(s) have been identified to meet the developments demands for playing field provision. This approach will also assist in ensuring Plan objectives F and J are met.
Ancillary Provision
To ensure that the playing field demand generated from sites in accordance with NPPF paragraph 96 the policy should incorporate the provision of supporting infrastructure required to serve the playing field sites, therefore the below additional text should be incorporated.
v. Financial contribution to provision of new playing pitches (and supporting ancillary provisions) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.
The wording of paragraph 594 should be made clear that the replacement provision should be equivalent or better provision in terms quantity and quality to ensure consistency with NPPF paragraph 97. Further to this new sports provision would also be required to meet the demand generated from the new developments.
In relation to shortlisted replacement sites further details should be provided to ascertain the sites suitability and further clarification is required as to what part of P20 is an enabling policy for replacement pitches and facilities.
For clarity paragraph 594 should be amended as per the below:
Sports and Recreation - Replacement of any lost recreation / sports provision as a result of development will be required to an equivalent or better standard in terms of quantity and quality, including ancillary provision, access and use by the wider community where appropriate. Provision will also be made for playing pitches (and ancillary provision) to meet the demands generated from new developments. Several sites have been shortlisted in the vicinity of the existing clubs West of Dickens Heath, and an enabling policy for replacement pitches and facilities is incorporated within Policy P20

Policy BL1 sets out the existing sports facilities should be retained and remain accessible until such time replacement sites are in place, which is supported by Sport England.
However Policy BL1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To enable the sporting needs from the development are met in line with Playing Pitch Strategy and NPPF paragraph 96 the following change is proposed:
-iii Relocation of the existing sports provision. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Paragraph 605 incorrectly sets out the sports club sites to be relocated with Leafield Athletic FC being retained and Wychall Wanderers FC to be replaced. To ensure clarity as to the site’s to be replaced the following modification is proposed.
605 The larger site is currently occupied by Highgate United FC, Leafield FC Wychall Wanderers FC and Old Yardleians .Rugby Football Club, and re-provision will be required for these sports pitches.

Policy BL2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy BL3 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy HH1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

The allocation of KN1 would entail the relocation of Knowle Football Club within the site on land between the new development and the canal. The policy states that appropriate facilities associated with the provision of outdoor sport will be permitted in the Green Belt, provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
To ensure the current site can be relocated in the area identified within the concept illustrative masterplan, the policy should make clear the replacement entails pitches and ancillary provision (such as floodlighting, clubhouse and car parking). Further to this provisions should be made within the policy to enable the capability of the site containing a 3G pitch in line with recommendations contained within the Council’s Playing Pitch Strategy and the Football Foundations Local Facilities Football Plan to ensure demand in the area can be met.
With regards to the illustrative concept masterplan Sport England and national governing bodies are keen to be engaged with the layout of the replacement site as there are some concerns based on concept such as:
- the introduction of trees within the central areas of the replacement playing field area would reduce the flexibility of the site to be marked out for alternative pitch layouts.
- car parking is detached from the sports pavilion;
- pavilion should be centrally located to the main pitch it seeks to serve
- Pitch orientation should accord with Sport England’s Natural Turf for Sport Guidance which is endorsed by national governing bodies.
- Seek to ensure the provision of sports light and the potential for a 3G pitch is not impacted by the LWS, Listed Buildings or proximity to residential dwellings.
- Cricket pitch should be sited in an area which would be impact by ball strike.
Policy KN1 would result in residential development adjacent an existing cricket club the policy fails to identify this as a principle which should be taken account of within the concept masterplan. The policy should reflect the requirements of NPPF paragraph 182 requiring a ball strike assessment to be undertaken should residential development come forward on the football club site but not on the cricket club site. The findings of the ball strike assessment should be implemented and maintained by the developer (unless of otherwise agreed by the Club following consultation with Sport England and the ECB). It is viewed that this is necessary as the proposed development could be at risk of ball strike which could prejudice the use of the cricket pitch.
a) To ensure replacement provision is equivalent in terms of quantity and quality in line with NPPF paragraph 97 and Sport England Exception Policy E4 the following modification is considered necessary:
viii. Relocation of the existing playing field site (pitches and ancillary provision) sports pitches currently occupied by Knowle Football Club;
b) For consistency and clarity purposes all reference to the reprovision/relocation of the Knowle pitches within the policy and supporting text should be modified to playing field site (pitches and ancillary provision)
c) To ensure that the use of the cricket club is not prejudiced by the introduction of residential development adjacent to it the following design principle in line NPPF paragraph 182 should be incorporated into the Policy:
2.IX The provision and maintenance of ball stop mitigation will be required, if deemed necessary following a ball strike risk assessment, and implemented before any ball strike risk is introduced as a result of the proposed development.
d) To enable an identified need within the Council’s Playing Pitch Strategy and Playing Pitch Mitigation Strategy to be met at the site, in accordance with NPPF paragraph 96, provisions within the policy for a 3G pitch should be made within the replacement site.
4.IV The provision for a full sized 3G pitch with sports lighting to be provided at the site.

Policy KN2 entails the relocation of the Arden Academy site. The Academy’s playing field site contains hard court provision, AGP and a number of playing pitches. The Council’s Playing Pitch Strategy identifies that there are current and future shortfalls in playing field provision. The Playing Pitch Strategy identifies that the site is used by the community, which should be formal secured via a community use agreement, and that sports provision should be replaced. In relation to the AGP the Playing Pitch Strategy states that it should replaced by a 3G pitch instead. Given the above the playing field site is not deemed to be surplus to requirement and the policy should ensure the playing field site should not be lost until a replacement provision of equivalent quantity and quality being developed and available for use.
Policy KN2 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
a) To ensure the policy is consistent with NPPF paragraph 97b, as the playing field site incorporating hard court and AGP has not been demonstrated to be surplus to requirement by the Playing Pitch Strategy and utilised by the community, the following modification is proposed to policy KN2:
2. x Development of the Arden Academy Trust playing field site (inclusive of hard court and AGP) and its ancillary facilities shall not commence until the provision of replacement playing field is made available for use. The replacement provision will be at least equivalent or better in terms quantity and quality of that proposed to be lost.
b) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy ME1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO1 identifies that the existing sports pitches are to be retained. Sport England consider that wording sports pitches should be replaced with ‘playing field site’ which is aligned to the wording of NPPF paragraph 97. Further to this the sports pitch layout within a playing field can alter and is not fixed on the site.
Sport England considers this modification is necessary as it would appear that the illustrative concept masterplan for the site has a road which encroaches on to the playing field site reducing the capability of site to accommodate pitches (reducing the size of pitches). No information has been submitted to justify the loss of playing field land in accordance with NPPF paragraph 97/Sport England’s Exception Policies.
Policy SO1 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
A) To ensure the policy wording in relation to the retention of existing playing field site in accordance with NPPF paragraph 97 the following modification is proposed:
V. iii. Retention of existing sports pitch playing field site.
B) For clarity the Concept Illustrative Masterplan should clearly set out there is no encroachment on to the playing field site.
C) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Sport England welcomes the identification of the provision of leisure and community infrastructure though the needs for the site should be informed by a Playing Pitch Strategy and Indoor Needs Assessment. To ensure that the leisure provision and playing pitch demand generated for the site is met the policy/supporting text should make reference to the need to undertake a site specific leisure and playing pitch needs assessment to inform the requirements for the site.

Sport England are supportive of policy UK2 with it ensuring the retention of the existing sports provision site until a suitable alternative site, agreed with Sport England and national governing bodies, being provided and ready for use.

Provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy P14 sets out how developments which will cause or be subject to existing
noise, odour or atmospheric pollution, will need to satisfactorily mitigate or abate the identified negative impact on amenity.
The Policy in part covers NPPF paragraph 182 agent of change principle. However, it fails to consider circumstances such as a developments adjacent playing field site for example a cricket club, which could be at risk of ball strike. In such circumstances, in line with NPPF paragraph 182, the development would need to provide mitigation through the provision of ball stop netting to ensure the use of the playing field is not prejudiced or that any unreasonable restrictions are placed on the use of the site.
An additional criterion should be added to Policy P14 to ensure consistency with national planning policy paragraph 182.
* Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed.

Policy P15 could be made more effective in promoting health and well-being, in line with NPPF paragraph 127, by referring to Sport England’s Active Design Guid-ance. The Guidance sets out 10 principles which developments should seek to ad-here to promote activity, health and stronger communities through design.
Active Design is supported by Public Health England and is part of our collabora-tive action to promote the principles set out in Public Health England’s ‘Everybody Active, Every Day’, to create active environments that make physical activity the easiest and most practical option in everyday life.
Add reference to point Policy P15 point 4 to help achieve Objectives F, H and J -
4. All developments should comply with the urban design principles set out in es-tablished current design guidance, including at present; The National Design Guide (2019), Urban Design Compendium 1 and 2 (2007), Manual for Streets 1 (2007) and 2 (2010), Active Design (20015), Building for Life 12 and Secured by Design principles, or their equivalents.

Sport England are supportive of Policy P18 Health and Wellbeing with it containing a number of Active Design Principles which help to promote physical activity.
Sport England considers the policy could be made more effective through the promotion of co-location (the grouping of destinations such as community facilities, schools, shops, work places, sports facilities and leisure centres within close proximity of each other), allowing users to make only one linked trip to an area for multiple reasons. Co-location assists with linked trips reducing the need to travel and allow more time for people to linger and be socially interactive, whilst also creating variety and vitality in town and local centres.
Linked to the above supporting infrastructure should also be promoted such as public conveniences; drinking fountains; cycle, mobility scooter and pushchair storage; changing rooms; quality of seating; Wi-Fi access; shelter and showers. The above are all elements that can influence physical activity choices and should be provided where appropriate to meet the needs of a range of potential users.
Supporting infrastructure to enable sport and physical activity to take place should be provided across all contexts including workplaces, sports facilities and public space, to facilitate all forms of activity.
Provision of new public open space, children’s play, sports and recreational facilities
Point 7 sets out new housing development will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, in line with the minimum standard of 3.57ha per 1,000 population.
The Council’s Playing Pitch Strategy Update and Playing Pitch Mitigation utilises Sport England’s Playing Pitch Demand Calculator Tool to ascertain the playing pitch demand from proposed housing allocations contained within the Plan.
Sport England promotes the use of the calculator with it being informed by a local evidence base document assessment of supply and demand. It is unclear if the standard of 3.57ha per 1,000 population encapsulates playing field provision and if so, how has the figure been justified to identify demand in line with Playing Pitch Strategy and whether it would meet the CIL regulation 122 tests.
Provision of new public open space, children’s play, sports and recreational facilities
Point 9 states new housing developments will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated. It is unclear why the viability caveat is included particularly given Policy P21 and the Plan’s objectives F and J, it might be the circumstances that other contributions should not be sought or that contributions should be proportionality reduced.
Indoor Sports Facilities Strategy 2012

Policy P20 points 10 and 13 refers to an Indoor Sports Facilities Strategy 2012. The document sets out provision standards based on deficit and surpluses for the Borough and then applies these standards to the 2026 projected future population of the Borough. Therefore, the standards proposed and identified deficits/surpluses are not based on robust and up to date assessment of need as there is a failure to consider needs up to 2036.
On the basis of the above the policy (and the IDP) is not consistent with national planning policy with NPPF paragraph 96, which requires planning policies to be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision.
Playing Pitch Strategy
Sport England welcomes the authority undertaking a monitoring and review of its Playing Pitch Strategy 2017. The Playing Pitch Strategy (update) 2019 provides an update on the following inputs amongst others; sites (where informed by national governing bodies and the LPA); team numbers (informed by national governing bodies); strategy period (extending from 2026 to 2036); and site actions.
The update document reaffirms that there are current and future shortfalls in playing field provision within the Borough. Therefore, to ensure demand for pitches are met there is a need to protect existing sites; provide new sites and to improve the quality of the existing sites where identified within the Playing Pitch Strategy Action Plan. The document also provides a robust evidence base to inform the Playing Pitch Mitigation Strategy which establishes the need to replace existing playing field sites proposed for development and identify the playing pitch demands from residential developments. The use of the Playing Pitch Strategy Mitigation report within the site allocations policies contained within the Plan is welcomed and in line with NPPF paragraph 96.
It should be noted dialogue with the LPA as part of the PPS update work confirmed that the authority will conduct a full Playing Pitch Strategy in early 2022, this is supported by Sport England to ensure that authority evidence base remains robust. It should be noted that the authority should still undertake annual reviews in line with Stage E of Sport England’s Playing Pitch Strategy Guidance.
1. The incorporation of the below text within P20 ensures that the demand for playing pitches will be informed/justified by evidence namely the Council’s Playing Pitch Strategy in line with NPPF paragraph 96.
Developer contributions will be required to enhance provision of playing pitch-es, based on additional demand generated by the new residential development and the sufficiency of existing provision to meet current and projected need. The Council will have regard to Sport England’s strategic planning tools and findings of the Playing Pitch Strategy to determine an appropriate amount and type of contribution or provision within new developments.
Where it is agreed by the Council that on-site pitch provision is appropriate to meet identified demand, the applicant is required to provide the new pitch(es) and make provision for its management and maintenance in perpetuity, and clarify these arrangements within a management plan to be agreed by the Council.
2. To ensure that the policy is effective in achieving its objective and policies considerations are not replicated the following amendment is suggested:
New housing developments will be required to provide or contribute to-wards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated.
3. Indoor Sports Facilities Strategy 2012
The authority should commit to updating its Indoor Sports Facilities Strategy 2012 with works commencing prior to the adoption of the Plan to ensure the Plan is consistent with NPPF paragraph 96.

Policy BC2 2. V states the retention of the existing playing field site which is welcomed and in line with the finding of the Playing Pitch Strategy. However, SMBC illustrative concept masterplan appears to display a road abutting the playing field site and the removal of part of a hedgerow which creates a boundary for the playing field site. It is unclear why this has been proposed as it could lead impact on the use of the site such as it being less secure and balls leaving the playing field site.
To ensure that there is reduced impact on the use of playing field the concept masterplan should maintain a strong boundary for the playing field site.
Sport England welcomes the vast majority of the proposed housing allocation policies identifying a need to provide a financial contribution towards the provision of new playing pitches and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy and the Playing Pitch Strategy which identified that there are current and future shortfalls in pitch provision.
However, at this point in time it is unclear as to where the contributions will be directed to with the Plan failing to identify the location or allocation of the new playing pitches/hubs sites.
Further to this on the larger proposed allocation sites (sites which generate the demand for multiple pitches) the illustrative concept masterplans fail to incorporate any on-site playing pitch provision As such there is a possibility that no additional pitches are created which could lead to the deterioration of existing pitches (which already in short supply) due to their use being exacerbated even further.
It should also be noted that ancillary uses such as car parking and changing room facilities will also be required to support the use of playing field sites for formal activities in line with the Playing Pitch Strategy.
Pitch Provision
To ensure the shortfalls identified within the Playing Pitch Strategy is met in accordance with NPPF paragraph 96 the Concept Illustrative Masterplans for sites which create the demand for multi playing pitches should clearly display locations for the pitches and ancillary provision. The need to provide for the pitches will rescind upon such time suitable new off site playing field site(s) have been identified to meet the developments demands for playing field provision. This approach will also assist in ensuring Plan objectives F and J are met.
Ancillary Provision
To ensure that the playing field demand generated from sites in accordance with NPPF paragraph 96 the policy should incorporate the provision of supporting infrastructure required to serve the playing field sites, therefore the below additional text should be incorporated.
v. Financial contribution to provision of new playing pitches (and supporting ancillary provisions) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.
The wording of paragraph 594 should be made clear that the replacement provision should be equivalent or better provision in terms quantity and quality to ensure consistency with NPPF paragraph 97. Further to this new sports provision would also be required to meet the demand generated from the new developments.
In relation to shortlisted replacement sites further details should be provided to ascertain the sites suitability and further clarification is required as to what part of P20 is an enabling policy for replacement pitches and facilities.
For clarity paragraph 594 should be amended as per the below:
Sports and Recreation - Replacement of any lost recreation / sports provision as a result of development will be required to an equivalent or better standard in terms of quantity and quality, including ancillary provision, access and use by the wider community where appropriate. Provision will also be made for playing pitches (and ancillary provision) to meet the demands generated from new developments. Several sites have been shortlisted in the vicinity of the existing clubs West of Dickens Heath, and an enabling policy for replacement pitches and facilities is incorporated within Policy P20

Policy BL1 sets out the existing sports facilities should be retained and remain accessible until such time replacement sites are in place, which is supported by Sport England.
However Policy BL1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To enable the sporting needs from the development are met in line with Playing Pitch Strategy and NPPF paragraph 96 the following change is proposed:
-iii Relocation of the existing sports provision. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Paragraph 605 incorrectly sets out the sports club sites to be relocated with Leafield Athletic FC being retained and Wychall Wanderers FC to be replaced. To ensure clarity as to the site’s to be replaced the following modification is proposed.
605 The larger site is currently occupied by Highgate United FC, Leafield FC Wychall Wanderers FC and Old Yardleians .Rugby Football Club, and re-provision will be required for these sports pitches.

Policy BL2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy BL3 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy HH1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

The allocation of KN1 would entail the relocation of Knowle Football Club within the site on land between the new development and the canal. The policy states that appropriate facilities associated with the provision of outdoor sport will be permitted in the Green Belt, provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
To ensure the current site can be relocated in the area identified within the concept illustrative masterplan, the policy should make clear the replacement entails pitches and ancillary provision (such as floodlighting, clubhouse and car parking). Further to this provisions should be made within the policy to enable the capability of the site containing a 3G pitch in line with recommendations contained within the Council’s Playing Pitch Strategy and the Football Foundations Local Facilities Football Plan to ensure demand in the area can be met.
With regards to the illustrative concept masterplan Sport England and national governing bodies are keen to be engaged with the layout of the replacement site as there are some concerns based on concept such as:
- the introduction of trees within the central areas of the replacement playing field area would reduce the flexibility of the site to be marked out for alternative pitch layouts.
- car parking is detached from the sports pavilion;
- pavilion should be centrally located to the main pitch it seeks to serve
- Pitch orientation should accord with Sport England’s Natural Turf for Sport Guidance which is endorsed by national governing bodies.
- Seek to ensure the provision of sports light and the potential for a 3G pitch is not impacted by the LWS, Listed Buildings or proximity to residential dwellings.
- Cricket pitch should be sited in an area which would be impact by ball strike.
Policy KN1 would result in residential development adjacent an existing cricket club the policy fails to identify this as a principle which should be taken account of within the concept masterplan. The policy should reflect the requirements of NPPF paragraph 182 requiring a ball strike assessment to be undertaken should residential development come forward on the football club site but not on the cricket club site. The findings of the ball strike assessment should be implemented and maintained by the developer (unless of otherwise agreed by the Club following consultation with Sport England and the ECB). It is viewed that this is necessary as the proposed development could be at risk of ball strike which could prejudice the use of the cricket pitch.
a) To ensure replacement provision is equivalent in terms of quantity and quality in line with NPPF paragraph 97 and Sport England Exception Policy E4 the following modification is considered necessary:
viii. Relocation of the existing playing field site (pitches and ancillary provision) sports pitches currently occupied by Knowle Football Club;
b) For consistency and clarity purposes all reference to the reprovision/relocation of the Knowle pitches within the policy and supporting text should be modified to playing field site (pitches and ancillary provision)
c) To ensure that the use of the cricket club is not prejudiced by the introduction of residential development adjacent to it the following design principle in line NPPF paragraph 182 should be incorporated into the Policy:
2.IX The provision and maintenance of ball stop mitigation will be required, if deemed necessary following a ball strike risk assessment, and implemented before any ball strike risk is introduced as a result of the proposed development.
d) To enable an identified need within the Council’s Playing Pitch Strategy and Playing Pitch Mitigation Strategy to be met at the site, in accordance with NPPF paragraph 96, provisions within the policy for a 3G pitch should be made within the replacement site.
4.IV The provision for a full sized 3G pitch with sports lighting to be provided at the site.

Policy KN2 entails the relocation of the Arden Academy site. The Academy’s playing field site contains hard court provision, AGP and a number of playing pitches. The Council’s Playing Pitch Strategy identifies that there are current and future shortfalls in playing field provision. The Playing Pitch Strategy identifies that the site is used by the community, which should be formal secured via a community use agreement, and that sports provision should be replaced. In relation to the AGP the Playing Pitch Strategy states that it should replaced by a 3G pitch instead. Given the above the playing field site is not deemed to be surplus to requirement and the policy should ensure the playing field site should not be lost until a replacement provision of equivalent quantity and quality being developed and available for use.
Policy KN2 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
a) To ensure the policy is consistent with NPPF paragraph 97b, as the playing field site incorporating hard court and AGP has not been demonstrated to be surplus to requirement by the Playing Pitch Strategy and utilised by the community, the following modification is proposed to policy KN2:
2. x Development of the Arden Academy Trust playing field site (inclusive of hard court and AGP) and its ancillary facilities shall not commence until the provision of replacement playing field is made available for use. The replacement provision will be at least equivalent or better in terms quantity and quality of that proposed to be lost.
b) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy ME1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO1 identifies that the existing sports pitches are to be retained. Sport England consider that wording sports pitches should be replaced with ‘playing field site’ which is aligned to the wording of NPPF paragraph 97. Further to this the sports pitch layout within a playing field can alter and is not fixed on the site.
Sport England considers this modification is necessary as it would appear that the illustrative concept masterplan for the site has a road which encroaches on to the playing field site reducing the capability of site to accommodate pitches (reducing the size of pitches). No information has been submitted to justify the loss of playing field land in accordance with NPPF paragraph 97/Sport England’s Exception Policies.
Policy SO1 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
A) To ensure the policy wording in relation to the retention of existing playing field site in accordance with NPPF paragraph 97 the following modification is proposed:
V. iii. Retention of existing sports pitch playing field site.
B) For clarity the Concept Illustrative Masterplan should clearly set out there is no encroachment on to the playing field site.
C) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Sport England welcomes the identification of the provision of leisure and community infrastructure though the needs for the site should be informed by a Playing Pitch Strategy and Indoor Needs Assessment. To ensure that the leisure provision and playing pitch demand generated for the site is met the policy/supporting text should make reference to the need to undertake a site specific leisure and playing pitch needs assessment to inform the requirements for the site.

Sport England are supportive of policy UK2 with it ensuring the retention of the existing sports provision site until a suitable alternative site, agreed with Sport England and national governing bodies, being provided and ready for use.

a) To ensure replacement provision is equivalent in terms of quantity and quality the following modification is considered necessary:
viii. Relocation of the existing playing field site (pitches and ancillary provision) sports pitches currently occupied by Knowle Football Club;
b) For consistency and clarity purposes all reference to the reprovision/relocation of the Knowle pitches within the policy and supporting text should be modified to playing field site (pitches and ancillary provision)
c) To ensure that the use of the cricket club is not prejudiced by the introduction of residential development adjacent to it the following design principle in line NPPF paragraph 182 should be incorporated into the Policy:
2.IX The provision and maintenance of ball stop mitigation will be required, if deemed necessary following a ball strike risk assessment, and implemented before any ball strike risk is introduced as a result of the proposed development.
d) To enable an identified need within the Council’s Playing Pitch Strategy and Playing Pitch Mitigation Strategy to be met at the site, in accordance with NPPF paragraph 96, provisions within the policy for a 3G pitch should be made within the replacement site.
4.IV The provision for a full sized 3G pitch with sports lighting to be provided at the site.

Policy P14 sets out how developments which will cause or be subject to existing
noise, odour or atmospheric pollution, will need to satisfactorily mitigate or abate the identified negative impact on amenity.
The Policy in part covers NPPF paragraph 182 agent of change principle. However, it fails to consider circumstances such as a developments adjacent playing field site for example a cricket club, which could be at risk of ball strike. In such circumstances, in line with NPPF paragraph 182, the development would need to provide mitigation through the provision of ball stop netting to ensure the use of the playing field is not prejudiced or that any unreasonable restrictions are placed on the use of the site.
An additional criterion should be added to Policy P14 to ensure consistency with national planning policy paragraph 182.
* Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed.

Policy P15 could be made more effective in promoting health and well-being, in line with NPPF paragraph 127, by referring to Sport England’s Active Design Guid-ance. The Guidance sets out 10 principles which developments should seek to ad-here to promote activity, health and stronger communities through design.
Active Design is supported by Public Health England and is part of our collabora-tive action to promote the principles set out in Public Health England’s ‘Everybody Active, Every Day’, to create active environments that make physical activity the easiest and most practical option in everyday life.
Add reference to point Policy P15 point 4 to help achieve Objectives F, H and J -
4. All developments should comply with the urban design principles set out in es-tablished current design guidance, including at present; The National Design Guide (2019), Urban Design Compendium 1 and 2 (2007), Manual for Streets 1 (2007) and 2 (2010), Active Design (20015), Building for Life 12 and Secured by Design principles, or their equivalents.

Sport England are supportive of Policy P18 Health and Wellbeing with it containing a number of Active Design Principles which help to promote physical activity.
Sport England considers the policy could be made more effective through the promotion of co-location (the grouping of destinations such as community facilities, schools, shops, work places, sports facilities and leisure centres within close proximity of each other), allowing users to make only one linked trip to an area for multiple reasons. Co-location assists with linked trips reducing the need to travel and allow more time for people to linger and be socially interactive, whilst also creating variety and vitality in town and local centres.
Linked to the above supporting infrastructure should also be promoted such as public conveniences; drinking fountains; cycle, mobility scooter and pushchair storage; changing rooms; quality of seating; Wi-Fi access; shelter and showers. The above are all elements that can influence physical activity choices and should be provided where appropriate to meet the needs of a range of potential users.
Supporting infrastructure to enable sport and physical activity to take place should be provided across all contexts including workplaces, sports facilities and public space, to facilitate all forms of activity.
Provision of new public open space, children’s play, sports and recreational facilities
Point 7 sets out new housing development will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, in line with the minimum standard of 3.57ha per 1,000 population.
The Council’s Playing Pitch Strategy Update and Playing Pitch Mitigation utilises Sport England’s Playing Pitch Demand Calculator Tool to ascertain the playing pitch demand from proposed housing allocations contained within the Plan.
Sport England promotes the use of the calculator with it being informed by a local evidence base document assessment of supply and demand. It is unclear if the standard of 3.57ha per 1,000 population encapsulates playing field provision and if so, how has the figure been justified to identify demand in line with Playing Pitch Strategy and whether it would meet the CIL regulation 122 tests.
Provision of new public open space, children’s play, sports and recreational facilities
Point 9 states new housing developments will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated. It is unclear why the viability caveat is included particularly given Policy P21 and the Plan’s objectives F and J, it might be the circumstances that other contributions should not be sought or that contributions should be proportionality reduced.
Indoor Sports Facilities Strategy 2012

Policy P20 points 10 and 13 refers to an Indoor Sports Facilities Strategy 2012. The document sets out provision standards based on deficit and surpluses for the Borough and then applies these standards to the 2026 projected future population of the Borough. Therefore, the standards proposed and identified deficits/surpluses are not based on robust and up to date assessment of need as there is a failure to consider needs up to 2036.
On the basis of the above the policy (and the IDP) is not consistent with national planning policy with NPPF paragraph 96, which requires planning policies to be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision.
Playing Pitch Strategy
Sport England welcomes the authority undertaking a monitoring and review of its Playing Pitch Strategy 2017. The Playing Pitch Strategy (update) 2019 provides an update on the following inputs amongst others; sites (where informed by national governing bodies and the LPA); team numbers (informed by national governing bodies); strategy period (extending from 2026 to 2036); and site actions.
The update document reaffirms that there are current and future shortfalls in playing field provision within the Borough. Therefore, to ensure demand for pitches are met there is a need to protect existing sites; provide new sites and to improve the quality of the existing sites where identified within the Playing Pitch Strategy Action Plan. The document also provides a robust evidence base to inform the Playing Pitch Mitigation Strategy which establishes the need to replace existing playing field sites proposed for development and identify the playing pitch demands from residential developments. The use of the Playing Pitch Strategy Mitigation report within the site allocations policies contained within the Plan is welcomed and in line with NPPF paragraph 96.
It should be noted dialogue with the LPA as part of the PPS update work confirmed that the authority will conduct a full Playing Pitch Strategy in early 2022, this is supported by Sport England to ensure that authority evidence base remains robust. It should be noted that the authority should still undertake annual reviews in line with Stage E of Sport England’s Playing Pitch Strategy Guidance.
1. The incorporation of the below text within P20 ensures that the demand for playing pitches will be informed/justified by evidence namely the Council’s Playing Pitch Strategy in line with NPPF paragraph 96.
Developer contributions will be required to enhance provision of playing pitch-es, based on additional demand generated by the new residential development and the sufficiency of existing provision to meet current and projected need. The Council will have regard to Sport England’s strategic planning tools and findings of the Playing Pitch Strategy to determine an appropriate amount and type of contribution or provision within new developments.
Where it is agreed by the Council that on-site pitch provision is appropriate to meet identified demand, the applicant is required to provide the new pitch(es) and make provision for its management and maintenance in perpetuity, and clarify these arrangements within a management plan to be agreed by the Council.
2. To ensure that the policy is effective in achieving its objective and policies considerations are not replicated the following amendment is suggested:
New housing developments will be required to provide or contribute to-wards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated.
3. Indoor Sports Facilities Strategy 2012
The authority should commit to updating its Indoor Sports Facilities Strategy 2012 with works commencing prior to the adoption of the Plan to ensure the Plan is consistent with NPPF paragraph 96.

Policy BC2 2. V states the retention of the existing playing field site which is welcomed and in line with the finding of the Playing Pitch Strategy. However, SMBC illustrative concept masterplan appears to display a road abutting the playing field site and the removal of part of a hedgerow which creates a boundary for the playing field site. It is unclear why this has been proposed as it could lead impact on the use of the site such as it being less secure and balls leaving the playing field site.
To ensure that there is reduced impact on the use of playing field the concept masterplan should maintain a strong boundary for the playing field site.
Sport England welcomes the vast majority of the proposed housing allocation policies identifying a need to provide a financial contribution towards the provision of new playing pitches and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy and the Playing Pitch Strategy which identified that there are current and future shortfalls in pitch provision.
However, at this point in time it is unclear as to where the contributions will be directed to with the Plan failing to identify the location or allocation of the new playing pitches/hubs sites.
Further to this on the larger proposed allocation sites (sites which generate the demand for multiple pitches) the illustrative concept masterplans fail to incorporate any on-site playing pitch provision As such there is a possibility that no additional pitches are created which could lead to the deterioration of existing pitches (which already in short supply) due to their use being exacerbated even further.
It should also be noted that ancillary uses such as car parking and changing room facilities will also be required to support the use of playing field sites for formal activities in line with the Playing Pitch Strategy.
Pitch Provision
To ensure the shortfalls identified within the Playing Pitch Strategy is met in accordance with NPPF paragraph 96 the Concept Illustrative Masterplans for sites which create the demand for multi playing pitches should clearly display locations for the pitches and ancillary provision. The need to provide for the pitches will rescind upon such time suitable new off site playing field site(s) have been identified to meet the developments demands for playing field provision. This approach will also assist in ensuring Plan objectives F and J are met.
Ancillary Provision
To ensure that the playing field demand generated from sites in accordance with NPPF paragraph 96 the policy should incorporate the provision of supporting infrastructure required to serve the playing field sites, therefore the below additional text should be incorporated.
v. Financial contribution to provision of new playing pitches (and supporting ancillary provisions) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.
The wording of paragraph 594 should be made clear that the replacement provision should be equivalent or better provision in terms quantity and quality to ensure consistency with NPPF paragraph 97. Further to this new sports provision would also be required to meet the demand generated from the new developments.
In relation to shortlisted replacement sites further details should be provided to ascertain the sites suitability and further clarification is required as to what part of P20 is an enabling policy for replacement pitches and facilities.
For clarity paragraph 594 should be amended as per the below:
Sports and Recreation - Replacement of any lost recreation / sports provision as a result of development will be required to an equivalent or better standard in terms of quantity and quality, including ancillary provision, access and use by the wider community where appropriate. Provision will also be made for playing pitches (and ancillary provision) to meet the demands generated from new developments. Several sites have been shortlisted in the vicinity of the existing clubs West of Dickens Heath, and an enabling policy for replacement pitches and facilities is incorporated within Policy P20

Policy BL1 sets out the existing sports facilities should be retained and remain accessible until such time replacement sites are in place, which is supported by Sport England.
However Policy BL1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To enable the sporting needs from the development are met in line with Playing Pitch Strategy and NPPF paragraph 96 the following change is proposed:
-iii Relocation of the existing sports provision. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Paragraph 605 incorrectly sets out the sports club sites to be relocated with Leafield Athletic FC being retained and Wychall Wanderers FC to be replaced. To ensure clarity as to the site’s to be replaced the following modification is proposed.
605 The larger site is currently occupied by Highgate United FC, Leafield FC Wychall Wanderers FC and Old Yardleians .Rugby Football Club, and re-provision will be required for these sports pitches.

Policy BL2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy BL3 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy HH1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

The allocation of KN1 would entail the relocation of Knowle Football Club within the site on land between the new development and the canal. The policy states that appropriate facilities associated with the provision of outdoor sport will be permitted in the Green Belt, provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
To ensure the current site can be relocated in the area identified within the concept illustrative masterplan, the policy should make clear the replacement entails pitches and ancillary provision (such as floodlighting, clubhouse and car parking). Further to this provisions should be made within the policy to enable the capability of the site containing a 3G pitch in line with recommendations contained within the Council’s Playing Pitch Strategy and the Football Foundations Local Facilities Football Plan to ensure demand in the area can be met.
With regards to the illustrative concept masterplan Sport England and national governing bodies are keen to be engaged with the layout of the replacement site as there are some concerns based on concept such as:
- the introduction of trees within the central areas of the replacement playing field area would reduce the flexibility of the site to be marked out for alternative pitch layouts.
- car parking is detached from the sports pavilion;
- pavilion should be centrally located to the main pitch it seeks to serve
- Pitch orientation should accord with Sport England’s Natural Turf for Sport Guidance which is endorsed by national governing bodies.
- Seek to ensure the provision of sports light and the potential for a 3G pitch is not impacted by the LWS, Listed Buildings or proximity to residential dwellings.
- Cricket pitch should be sited in an area which would be impact by ball strike.
Policy KN1 would result in residential development adjacent an existing cricket club the policy fails to identify this as a principle which should be taken account of within the concept masterplan. The policy should reflect the requirements of NPPF paragraph 182 requiring a ball strike assessment to be undertaken should residential development come forward on the football club site but not on the cricket club site. The findings of the ball strike assessment should be implemented and maintained by the developer (unless of otherwise agreed by the Club following consultation with Sport England and the ECB). It is viewed that this is necessary as the proposed development could be at risk of ball strike which could prejudice the use of the cricket pitch.
a) To ensure replacement provision is equivalent in terms of quantity and quality in line with NPPF paragraph 97 and Sport England Exception Policy E4 the following modification is considered necessary:
viii. Relocation of the existing playing field site (pitches and ancillary provision) sports pitches currently occupied by Knowle Football Club;
b) For consistency and clarity purposes all reference to the reprovision/relocation of the Knowle pitches within the policy and supporting text should be modified to playing field site (pitches and ancillary provision)
c) To ensure that the use of the cricket club is not prejudiced by the introduction of residential development adjacent to it the following design principle in line NPPF paragraph 182 should be incorporated into the Policy:
2.IX The provision and maintenance of ball stop mitigation will be required, if deemed necessary following a ball strike risk assessment, and implemented before any ball strike risk is introduced as a result of the proposed development.
d) To enable an identified need within the Council’s Playing Pitch Strategy and Playing Pitch Mitigation Strategy to be met at the site, in accordance with NPPF paragraph 96, provisions within the policy for a 3G pitch should be made within the replacement site.
4.IV The provision for a full sized 3G pitch with sports lighting to be provided at the site.

Policy KN2 entails the relocation of the Arden Academy site. The Academy’s playing field site contains hard court provision, AGP and a number of playing pitches. The Council’s Playing Pitch Strategy identifies that there are current and future shortfalls in playing field provision. The Playing Pitch Strategy identifies that the site is used by the community, which should be formal secured via a community use agreement, and that sports provision should be replaced. In relation to the AGP the Playing Pitch Strategy states that it should replaced by a 3G pitch instead. Given the above the playing field site is not deemed to be surplus to requirement and the policy should ensure the playing field site should not be lost until a replacement provision of equivalent quantity and quality being developed and available for use.
Policy KN2 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
a) To ensure the policy is consistent with NPPF paragraph 97b, as the playing field site incorporating hard court and AGP has not been demonstrated to be surplus to requirement by the Playing Pitch Strategy and utilised by the community, the following modification is proposed to policy KN2:
2. x Development of the Arden Academy Trust playing field site (inclusive of hard court and AGP) and its ancillary facilities shall not commence until the provision of replacement playing field is made available for use. The replacement provision will be at least equivalent or better in terms quantity and quality of that proposed to be lost.
b) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy ME1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO1 identifies that the existing sports pitches are to be retained. Sport England consider that wording sports pitches should be replaced with ‘playing field site’ which is aligned to the wording of NPPF paragraph 97. Further to this the sports pitch layout within a playing field can alter and is not fixed on the site.
Sport England considers this modification is necessary as it would appear that the illustrative concept masterplan for the site has a road which encroaches on to the playing field site reducing the capability of site to accommodate pitches (reducing the size of pitches). No information has been submitted to justify the loss of playing field land in accordance with NPPF paragraph 97/Sport England’s Exception Policies.
Policy SO1 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
A) To ensure the policy wording in relation to the retention of existing playing field site in accordance with NPPF paragraph 97 the following modification is proposed:
V. iii. Retention of existing sports pitch playing field site.
B) For clarity the Concept Illustrative Masterplan should clearly set out there is no encroachment on to the playing field site.
C) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Sport England welcomes the identification of the provision of leisure and community infrastructure though the needs for the site should be informed by a Playing Pitch Strategy and Indoor Needs Assessment. To ensure that the leisure provision and playing pitch demand generated for the site is met the policy/supporting text should make reference to the need to undertake a site specific leisure and playing pitch needs assessment to inform the requirements for the site.

Sport England are supportive of policy UK2 with it ensuring the retention of the existing sports provision site until a suitable alternative site, agreed with Sport England and national governing bodies, being provided and ready for use.

The following modifications are proposed to policy KN2:
(a) New 2x Development of the Arden Academy Trust playing field site (inclusive of hard court and AGP) and its ancillary facilities shall not commence until the provision of replacement playing field is made available for use. The replacement provision will be at least equivalent or better in terms quantity and quality of that proposed to be lost.

(b) 3v Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy P14 sets out how developments which will cause or be subject to existing
noise, odour or atmospheric pollution, will need to satisfactorily mitigate or abate the identified negative impact on amenity.
The Policy in part covers NPPF paragraph 182 agent of change principle. However, it fails to consider circumstances such as a developments adjacent playing field site for example a cricket club, which could be at risk of ball strike. In such circumstances, in line with NPPF paragraph 182, the development would need to provide mitigation through the provision of ball stop netting to ensure the use of the playing field is not prejudiced or that any unreasonable restrictions are placed on the use of the site.
An additional criterion should be added to Policy P14 to ensure consistency with national planning policy paragraph 182.
* Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed.

Policy P15 could be made more effective in promoting health and well-being, in line with NPPF paragraph 127, by referring to Sport England’s Active Design Guid-ance. The Guidance sets out 10 principles which developments should seek to ad-here to promote activity, health and stronger communities through design.
Active Design is supported by Public Health England and is part of our collabora-tive action to promote the principles set out in Public Health England’s ‘Everybody Active, Every Day’, to create active environments that make physical activity the easiest and most practical option in everyday life.
Add reference to point Policy P15 point 4 to help achieve Objectives F, H and J -
4. All developments should comply with the urban design principles set out in es-tablished current design guidance, including at present; The National Design Guide (2019), Urban Design Compendium 1 and 2 (2007), Manual for Streets 1 (2007) and 2 (2010), Active Design (20015), Building for Life 12 and Secured by Design principles, or their equivalents.

Sport England are supportive of Policy P18 Health and Wellbeing with it containing a number of Active Design Principles which help to promote physical activity.
Sport England considers the policy could be made more effective through the promotion of co-location (the grouping of destinations such as community facilities, schools, shops, work places, sports facilities and leisure centres within close proximity of each other), allowing users to make only one linked trip to an area for multiple reasons. Co-location assists with linked trips reducing the need to travel and allow more time for people to linger and be socially interactive, whilst also creating variety and vitality in town and local centres.
Linked to the above supporting infrastructure should also be promoted such as public conveniences; drinking fountains; cycle, mobility scooter and pushchair storage; changing rooms; quality of seating; Wi-Fi access; shelter and showers. The above are all elements that can influence physical activity choices and should be provided where appropriate to meet the needs of a range of potential users.
Supporting infrastructure to enable sport and physical activity to take place should be provided across all contexts including workplaces, sports facilities and public space, to facilitate all forms of activity.
Provision of new public open space, children’s play, sports and recreational facilities
Point 7 sets out new housing development will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, in line with the minimum standard of 3.57ha per 1,000 population.
The Council’s Playing Pitch Strategy Update and Playing Pitch Mitigation utilises Sport England’s Playing Pitch Demand Calculator Tool to ascertain the playing pitch demand from proposed housing allocations contained within the Plan.
Sport England promotes the use of the calculator with it being informed by a local evidence base document assessment of supply and demand. It is unclear if the standard of 3.57ha per 1,000 population encapsulates playing field provision and if so, how has the figure been justified to identify demand in line with Playing Pitch Strategy and whether it would meet the CIL regulation 122 tests.
Provision of new public open space, children’s play, sports and recreational facilities
Point 9 states new housing developments will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated. It is unclear why the viability caveat is included particularly given Policy P21 and the Plan’s objectives F and J, it might be the circumstances that other contributions should not be sought or that contributions should be proportionality reduced.
Indoor Sports Facilities Strategy 2012

Policy P20 points 10 and 13 refers to an Indoor Sports Facilities Strategy 2012. The document sets out provision standards based on deficit and surpluses for the Borough and then applies these standards to the 2026 projected future population of the Borough. Therefore, the standards proposed and identified deficits/surpluses are not based on robust and up to date assessment of need as there is a failure to consider needs up to 2036.
On the basis of the above the policy (and the IDP) is not consistent with national planning policy with NPPF paragraph 96, which requires planning policies to be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision.
Playing Pitch Strategy
Sport England welcomes the authority undertaking a monitoring and review of its Playing Pitch Strategy 2017. The Playing Pitch Strategy (update) 2019 provides an update on the following inputs amongst others; sites (where informed by national governing bodies and the LPA); team numbers (informed by national governing bodies); strategy period (extending from 2026 to 2036); and site actions.
The update document reaffirms that there are current and future shortfalls in playing field provision within the Borough. Therefore, to ensure demand for pitches are met there is a need to protect existing sites; provide new sites and to improve the quality of the existing sites where identified within the Playing Pitch Strategy Action Plan. The document also provides a robust evidence base to inform the Playing Pitch Mitigation Strategy which establishes the need to replace existing playing field sites proposed for development and identify the playing pitch demands from residential developments. The use of the Playing Pitch Strategy Mitigation report within the site allocations policies contained within the Plan is welcomed and in line with NPPF paragraph 96.
It should be noted dialogue with the LPA as part of the PPS update work confirmed that the authority will conduct a full Playing Pitch Strategy in early 2022, this is supported by Sport England to ensure that authority evidence base remains robust. It should be noted that the authority should still undertake annual reviews in line with Stage E of Sport England’s Playing Pitch Strategy Guidance.
1. The incorporation of the below text within P20 ensures that the demand for playing pitches will be informed/justified by evidence namely the Council’s Playing Pitch Strategy in line with NPPF paragraph 96.
Developer contributions will be required to enhance provision of playing pitch-es, based on additional demand generated by the new residential development and the sufficiency of existing provision to meet current and projected need. The Council will have regard to Sport England’s strategic planning tools and findings of the Playing Pitch Strategy to determine an appropriate amount and type of contribution or provision within new developments.
Where it is agreed by the Council that on-site pitch provision is appropriate to meet identified demand, the applicant is required to provide the new pitch(es) and make provision for its management and maintenance in perpetuity, and clarify these arrangements within a management plan to be agreed by the Council.
2. To ensure that the policy is effective in achieving its objective and policies considerations are not replicated the following amendment is suggested:
New housing developments will be required to provide or contribute to-wards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated.
3. Indoor Sports Facilities Strategy 2012
The authority should commit to updating its Indoor Sports Facilities Strategy 2012 with works commencing prior to the adoption of the Plan to ensure the Plan is consistent with NPPF paragraph 96.

Policy BC2 2. V states the retention of the existing playing field site which is welcomed and in line with the finding of the Playing Pitch Strategy. However, SMBC illustrative concept masterplan appears to display a road abutting the playing field site and the removal of part of a hedgerow which creates a boundary for the playing field site. It is unclear why this has been proposed as it could lead impact on the use of the site such as it being less secure and balls leaving the playing field site.
To ensure that there is reduced impact on the use of playing field the concept masterplan should maintain a strong boundary for the playing field site.
Sport England welcomes the vast majority of the proposed housing allocation policies identifying a need to provide a financial contribution towards the provision of new playing pitches and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy and the Playing Pitch Strategy which identified that there are current and future shortfalls in pitch provision.
However, at this point in time it is unclear as to where the contributions will be directed to with the Plan failing to identify the location or allocation of the new playing pitches/hubs sites.
Further to this on the larger proposed allocation sites (sites which generate the demand for multiple pitches) the illustrative concept masterplans fail to incorporate any on-site playing pitch provision As such there is a possibility that no additional pitches are created which could lead to the deterioration of existing pitches (which already in short supply) due to their use being exacerbated even further.
It should also be noted that ancillary uses such as car parking and changing room facilities will also be required to support the use of playing field sites for formal activities in line with the Playing Pitch Strategy.
Pitch Provision
To ensure the shortfalls identified within the Playing Pitch Strategy is met in accordance with NPPF paragraph 96 the Concept Illustrative Masterplans for sites which create the demand for multi playing pitches should clearly display locations for the pitches and ancillary provision. The need to provide for the pitches will rescind upon such time suitable new off site playing field site(s) have been identified to meet the developments demands for playing field provision. This approach will also assist in ensuring Plan objectives F and J are met.
Ancillary Provision
To ensure that the playing field demand generated from sites in accordance with NPPF paragraph 96 the policy should incorporate the provision of supporting infrastructure required to serve the playing field sites, therefore the below additional text should be incorporated.
v. Financial contribution to provision of new playing pitches (and supporting ancillary provisions) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.
The wording of paragraph 594 should be made clear that the replacement provision should be equivalent or better provision in terms quantity and quality to ensure consistency with NPPF paragraph 97. Further to this new sports provision would also be required to meet the demand generated from the new developments.
In relation to shortlisted replacement sites further details should be provided to ascertain the sites suitability and further clarification is required as to what part of P20 is an enabling policy for replacement pitches and facilities.
For clarity paragraph 594 should be amended as per the below:
Sports and Recreation - Replacement of any lost recreation / sports provision as a result of development will be required to an equivalent or better standard in terms of quantity and quality, including ancillary provision, access and use by the wider community where appropriate. Provision will also be made for playing pitches (and ancillary provision) to meet the demands generated from new developments. Several sites have been shortlisted in the vicinity of the existing clubs West of Dickens Heath, and an enabling policy for replacement pitches and facilities is incorporated within Policy P20

Policy BL1 sets out the existing sports facilities should be retained and remain accessible until such time replacement sites are in place, which is supported by Sport England.
However Policy BL1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To enable the sporting needs from the development are met in line with Playing Pitch Strategy and NPPF paragraph 96 the following change is proposed:
-iii Relocation of the existing sports provision. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Paragraph 605 incorrectly sets out the sports club sites to be relocated with Leafield Athletic FC being retained and Wychall Wanderers FC to be replaced. To ensure clarity as to the site’s to be replaced the following modification is proposed.
605 The larger site is currently occupied by Highgate United FC, Leafield FC Wychall Wanderers FC and Old Yardleians .Rugby Football Club, and re-provision will be required for these sports pitches.

Policy BL2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy BL3 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy HH1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

The allocation of KN1 would entail the relocation of Knowle Football Club within the site on land between the new development and the canal. The policy states that appropriate facilities associated with the provision of outdoor sport will be permitted in the Green Belt, provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
To ensure the current site can be relocated in the area identified within the concept illustrative masterplan, the policy should make clear the replacement entails pitches and ancillary provision (such as floodlighting, clubhouse and car parking). Further to this provisions should be made within the policy to enable the capability of the site containing a 3G pitch in line with recommendations contained within the Council’s Playing Pitch Strategy and the Football Foundations Local Facilities Football Plan to ensure demand in the area can be met.
With regards to the illustrative concept masterplan Sport England and national governing bodies are keen to be engaged with the layout of the replacement site as there are some concerns based on concept such as:
- the introduction of trees within the central areas of the replacement playing field area would reduce the flexibility of the site to be marked out for alternative pitch layouts.
- car parking is detached from the sports pavilion;
- pavilion should be centrally located to the main pitch it seeks to serve
- Pitch orientation should accord with Sport England’s Natural Turf for Sport Guidance which is endorsed by national governing bodies.
- Seek to ensure the provision of sports light and the potential for a 3G pitch is not impacted by the LWS, Listed Buildings or proximity to residential dwellings.
- Cricket pitch should be sited in an area which would be impact by ball strike.
Policy KN1 would result in residential development adjacent an existing cricket club the policy fails to identify this as a principle which should be taken account of within the concept masterplan. The policy should reflect the requirements of NPPF paragraph 182 requiring a ball strike assessment to be undertaken should residential development come forward on the football club site but not on the cricket club site. The findings of the ball strike assessment should be implemented and maintained by the developer (unless of otherwise agreed by the Club following consultation with Sport England and the ECB). It is viewed that this is necessary as the proposed development could be at risk of ball strike which could prejudice the use of the cricket pitch.
a) To ensure replacement provision is equivalent in terms of quantity and quality in line with NPPF paragraph 97 and Sport England Exception Policy E4 the following modification is considered necessary:
viii. Relocation of the existing playing field site (pitches and ancillary provision) sports pitches currently occupied by Knowle Football Club;
b) For consistency and clarity purposes all reference to the reprovision/relocation of the Knowle pitches within the policy and supporting text should be modified to playing field site (pitches and ancillary provision)
c) To ensure that the use of the cricket club is not prejudiced by the introduction of residential development adjacent to it the following design principle in line NPPF paragraph 182 should be incorporated into the Policy:
2.IX The provision and maintenance of ball stop mitigation will be required, if deemed necessary following a ball strike risk assessment, and implemented before any ball strike risk is introduced as a result of the proposed development.
d) To enable an identified need within the Council’s Playing Pitch Strategy and Playing Pitch Mitigation Strategy to be met at the site, in accordance with NPPF paragraph 96, provisions within the policy for a 3G pitch should be made within the replacement site.
4.IV The provision for a full sized 3G pitch with sports lighting to be provided at the site.

Policy KN2 entails the relocation of the Arden Academy site. The Academy’s playing field site contains hard court provision, AGP and a number of playing pitches. The Council’s Playing Pitch Strategy identifies that there are current and future shortfalls in playing field provision. The Playing Pitch Strategy identifies that the site is used by the community, which should be formal secured via a community use agreement, and that sports provision should be replaced. In relation to the AGP the Playing Pitch Strategy states that it should replaced by a 3G pitch instead. Given the above the playing field site is not deemed to be surplus to requirement and the policy should ensure the playing field site should not be lost until a replacement provision of equivalent quantity and quality being developed and available for use.
Policy KN2 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
a) To ensure the policy is consistent with NPPF paragraph 97b, as the playing field site incorporating hard court and AGP has not been demonstrated to be surplus to requirement by the Playing Pitch Strategy and utilised by the community, the following modification is proposed to policy KN2:
2. x Development of the Arden Academy Trust playing field site (inclusive of hard court and AGP) and its ancillary facilities shall not commence until the provision of replacement playing field is made available for use. The replacement provision will be at least equivalent or better in terms quantity and quality of that proposed to be lost.
b) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy ME1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO1 identifies that the existing sports pitches are to be retained. Sport England consider that wording sports pitches should be replaced with ‘playing field site’ which is aligned to the wording of NPPF paragraph 97. Further to this the sports pitch layout within a playing field can alter and is not fixed on the site.
Sport England considers this modification is necessary as it would appear that the illustrative concept masterplan for the site has a road which encroaches on to the playing field site reducing the capability of site to accommodate pitches (reducing the size of pitches). No information has been submitted to justify the loss of playing field land in accordance with NPPF paragraph 97/Sport England’s Exception Policies.
Policy SO1 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
A) To ensure the policy wording in relation to the retention of existing playing field site in accordance with NPPF paragraph 97 the following modification is proposed:
V. iii. Retention of existing sports pitch playing field site.
B) For clarity the Concept Illustrative Masterplan should clearly set out there is no encroachment on to the playing field site.
C) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Sport England welcomes the identification of the provision of leisure and community infrastructure though the needs for the site should be informed by a Playing Pitch Strategy and Indoor Needs Assessment. To ensure that the leisure provision and playing pitch demand generated for the site is met the policy/supporting text should make reference to the need to undertake a site specific leisure and playing pitch needs assessment to inform the requirements for the site.

Sport England are supportive of policy UK2 with it ensuring the retention of the existing sports provision site until a suitable alternative site, agreed with Sport England and national governing bodies, being provided and ready for use.

The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy P14 sets out how developments which will cause or be subject to existing
noise, odour or atmospheric pollution, will need to satisfactorily mitigate or abate the identified negative impact on amenity.
The Policy in part covers NPPF paragraph 182 agent of change principle. However, it fails to consider circumstances such as a developments adjacent playing field site for example a cricket club, which could be at risk of ball strike. In such circumstances, in line with NPPF paragraph 182, the development would need to provide mitigation through the provision of ball stop netting to ensure the use of the playing field is not prejudiced or that any unreasonable restrictions are placed on the use of the site.
An additional criterion should be added to Policy P14 to ensure consistency with national planning policy paragraph 182.
* Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed.

Policy P15 could be made more effective in promoting health and well-being, in line with NPPF paragraph 127, by referring to Sport England’s Active Design Guid-ance. The Guidance sets out 10 principles which developments should seek to ad-here to promote activity, health and stronger communities through design.
Active Design is supported by Public Health England and is part of our collabora-tive action to promote the principles set out in Public Health England’s ‘Everybody Active, Every Day’, to create active environments that make physical activity the easiest and most practical option in everyday life.
Add reference to point Policy P15 point 4 to help achieve Objectives F, H and J -
4. All developments should comply with the urban design principles set out in es-tablished current design guidance, including at present; The National Design Guide (2019), Urban Design Compendium 1 and 2 (2007), Manual for Streets 1 (2007) and 2 (2010), Active Design (20015), Building for Life 12 and Secured by Design principles, or their equivalents.

Sport England are supportive of Policy P18 Health and Wellbeing with it containing a number of Active Design Principles which help to promote physical activity.
Sport England considers the policy could be made more effective through the promotion of co-location (the grouping of destinations such as community facilities, schools, shops, work places, sports facilities and leisure centres within close proximity of each other), allowing users to make only one linked trip to an area for multiple reasons. Co-location assists with linked trips reducing the need to travel and allow more time for people to linger and be socially interactive, whilst also creating variety and vitality in town and local centres.
Linked to the above supporting infrastructure should also be promoted such as public conveniences; drinking fountains; cycle, mobility scooter and pushchair storage; changing rooms; quality of seating; Wi-Fi access; shelter and showers. The above are all elements that can influence physical activity choices and should be provided where appropriate to meet the needs of a range of potential users.
Supporting infrastructure to enable sport and physical activity to take place should be provided across all contexts including workplaces, sports facilities and public space, to facilitate all forms of activity.
Provision of new public open space, children’s play, sports and recreational facilities
Point 7 sets out new housing development will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, in line with the minimum standard of 3.57ha per 1,000 population.
The Council’s Playing Pitch Strategy Update and Playing Pitch Mitigation utilises Sport England’s Playing Pitch Demand Calculator Tool to ascertain the playing pitch demand from proposed housing allocations contained within the Plan.
Sport England promotes the use of the calculator with it being informed by a local evidence base document assessment of supply and demand. It is unclear if the standard of 3.57ha per 1,000 population encapsulates playing field provision and if so, how has the figure been justified to identify demand in line with Playing Pitch Strategy and whether it would meet the CIL regulation 122 tests.
Provision of new public open space, children’s play, sports and recreational facilities
Point 9 states new housing developments will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated. It is unclear why the viability caveat is included particularly given Policy P21 and the Plan’s objectives F and J, it might be the circumstances that other contributions should not be sought or that contributions should be proportionality reduced.
Indoor Sports Facilities Strategy 2012

Policy P20 points 10 and 13 refers to an Indoor Sports Facilities Strategy 2012. The document sets out provision standards based on deficit and surpluses for the Borough and then applies these standards to the 2026 projected future population of the Borough. Therefore, the standards proposed and identified deficits/surpluses are not based on robust and up to date assessment of need as there is a failure to consider needs up to 2036.
On the basis of the above the policy (and the IDP) is not consistent with national planning policy with NPPF paragraph 96, which requires planning policies to be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision.
Playing Pitch Strategy
Sport England welcomes the authority undertaking a monitoring and review of its Playing Pitch Strategy 2017. The Playing Pitch Strategy (update) 2019 provides an update on the following inputs amongst others; sites (where informed by national governing bodies and the LPA); team numbers (informed by national governing bodies); strategy period (extending from 2026 to 2036); and site actions.
The update document reaffirms that there are current and future shortfalls in playing field provision within the Borough. Therefore, to ensure demand for pitches are met there is a need to protect existing sites; provide new sites and to improve the quality of the existing sites where identified within the Playing Pitch Strategy Action Plan. The document also provides a robust evidence base to inform the Playing Pitch Mitigation Strategy which establishes the need to replace existing playing field sites proposed for development and identify the playing pitch demands from residential developments. The use of the Playing Pitch Strategy Mitigation report within the site allocations policies contained within the Plan is welcomed and in line with NPPF paragraph 96.
It should be noted dialogue with the LPA as part of the PPS update work confirmed that the authority will conduct a full Playing Pitch Strategy in early 2022, this is supported by Sport England to ensure that authority evidence base remains robust. It should be noted that the authority should still undertake annual reviews in line with Stage E of Sport England’s Playing Pitch Strategy Guidance.
1. The incorporation of the below text within P20 ensures that the demand for playing pitches will be informed/justified by evidence namely the Council’s Playing Pitch Strategy in line with NPPF paragraph 96.
Developer contributions will be required to enhance provision of playing pitch-es, based on additional demand generated by the new residential development and the sufficiency of existing provision to meet current and projected need. The Council will have regard to Sport England’s strategic planning tools and findings of the Playing Pitch Strategy to determine an appropriate amount and type of contribution or provision within new developments.
Where it is agreed by the Council that on-site pitch provision is appropriate to meet identified demand, the applicant is required to provide the new pitch(es) and make provision for its management and maintenance in perpetuity, and clarify these arrangements within a management plan to be agreed by the Council.
2. To ensure that the policy is effective in achieving its objective and policies considerations are not replicated the following amendment is suggested:
New housing developments will be required to provide or contribute to-wards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated.
3. Indoor Sports Facilities Strategy 2012
The authority should commit to updating its Indoor Sports Facilities Strategy 2012 with works commencing prior to the adoption of the Plan to ensure the Plan is consistent with NPPF paragraph 96.

Policy BC2 2. V states the retention of the existing playing field site which is welcomed and in line with the finding of the Playing Pitch Strategy. However, SMBC illustrative concept masterplan appears to display a road abutting the playing field site and the removal of part of a hedgerow which creates a boundary for the playing field site. It is unclear why this has been proposed as it could lead impact on the use of the site such as it being less secure and balls leaving the playing field site.
To ensure that there is reduced impact on the use of playing field the concept masterplan should maintain a strong boundary for the playing field site.
Sport England welcomes the vast majority of the proposed housing allocation policies identifying a need to provide a financial contribution towards the provision of new playing pitches and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy and the Playing Pitch Strategy which identified that there are current and future shortfalls in pitch provision.
However, at this point in time it is unclear as to where the contributions will be directed to with the Plan failing to identify the location or allocation of the new playing pitches/hubs sites.
Further to this on the larger proposed allocation sites (sites which generate the demand for multiple pitches) the illustrative concept masterplans fail to incorporate any on-site playing pitch provision As such there is a possibility that no additional pitches are created which could lead to the deterioration of existing pitches (which already in short supply) due to their use being exacerbated even further.
It should also be noted that ancillary uses such as car parking and changing room facilities will also be required to support the use of playing field sites for formal activities in line with the Playing Pitch Strategy.
Pitch Provision
To ensure the shortfalls identified within the Playing Pitch Strategy is met in accordance with NPPF paragraph 96 the Concept Illustrative Masterplans for sites which create the demand for multi playing pitches should clearly display locations for the pitches and ancillary provision. The need to provide for the pitches will rescind upon such time suitable new off site playing field site(s) have been identified to meet the developments demands for playing field provision. This approach will also assist in ensuring Plan objectives F and J are met.
Ancillary Provision
To ensure that the playing field demand generated from sites in accordance with NPPF paragraph 96 the policy should incorporate the provision of supporting infrastructure required to serve the playing field sites, therefore the below additional text should be incorporated.
v. Financial contribution to provision of new playing pitches (and supporting ancillary provisions) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.
The wording of paragraph 594 should be made clear that the replacement provision should be equivalent or better provision in terms quantity and quality to ensure consistency with NPPF paragraph 97. Further to this new sports provision would also be required to meet the demand generated from the new developments.
In relation to shortlisted replacement sites further details should be provided to ascertain the sites suitability and further clarification is required as to what part of P20 is an enabling policy for replacement pitches and facilities.
For clarity paragraph 594 should be amended as per the below:
Sports and Recreation - Replacement of any lost recreation / sports provision as a result of development will be required to an equivalent or better standard in terms of quantity and quality, including ancillary provision, access and use by the wider community where appropriate. Provision will also be made for playing pitches (and ancillary provision) to meet the demands generated from new developments. Several sites have been shortlisted in the vicinity of the existing clubs West of Dickens Heath, and an enabling policy for replacement pitches and facilities is incorporated within Policy P20

Policy BL1 sets out the existing sports facilities should be retained and remain accessible until such time replacement sites are in place, which is supported by Sport England.
However Policy BL1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To enable the sporting needs from the development are met in line with Playing Pitch Strategy and NPPF paragraph 96 the following change is proposed:
-iii Relocation of the existing sports provision. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Paragraph 605 incorrectly sets out the sports club sites to be relocated with Leafield Athletic FC being retained and Wychall Wanderers FC to be replaced. To ensure clarity as to the site’s to be replaced the following modification is proposed.
605 The larger site is currently occupied by Highgate United FC, Leafield FC Wychall Wanderers FC and Old Yardleians .Rugby Football Club, and re-provision will be required for these sports pitches.

Policy BL2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy BL3 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy HH1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

The allocation of KN1 would entail the relocation of Knowle Football Club within the site on land between the new development and the canal. The policy states that appropriate facilities associated with the provision of outdoor sport will be permitted in the Green Belt, provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
To ensure the current site can be relocated in the area identified within the concept illustrative masterplan, the policy should make clear the replacement entails pitches and ancillary provision (such as floodlighting, clubhouse and car parking). Further to this provisions should be made within the policy to enable the capability of the site containing a 3G pitch in line with recommendations contained within the Council’s Playing Pitch Strategy and the Football Foundations Local Facilities Football Plan to ensure demand in the area can be met.
With regards to the illustrative concept masterplan Sport England and national governing bodies are keen to be engaged with the layout of the replacement site as there are some concerns based on concept such as:
- the introduction of trees within the central areas of the replacement playing field area would reduce the flexibility of the site to be marked out for alternative pitch layouts.
- car parking is detached from the sports pavilion;
- pavilion should be centrally located to the main pitch it seeks to serve
- Pitch orientation should accord with Sport England’s Natural Turf for Sport Guidance which is endorsed by national governing bodies.
- Seek to ensure the provision of sports light and the potential for a 3G pitch is not impacted by the LWS, Listed Buildings or proximity to residential dwellings.
- Cricket pitch should be sited in an area which would be impact by ball strike.
Policy KN1 would result in residential development adjacent an existing cricket club the policy fails to identify this as a principle which should be taken account of within the concept masterplan. The policy should reflect the requirements of NPPF paragraph 182 requiring a ball strike assessment to be undertaken should residential development come forward on the football club site but not on the cricket club site. The findings of the ball strike assessment should be implemented and maintained by the developer (unless of otherwise agreed by the Club following consultation with Sport England and the ECB). It is viewed that this is necessary as the proposed development could be at risk of ball strike which could prejudice the use of the cricket pitch.
a) To ensure replacement provision is equivalent in terms of quantity and quality in line with NPPF paragraph 97 and Sport England Exception Policy E4 the following modification is considered necessary:
viii. Relocation of the existing playing field site (pitches and ancillary provision) sports pitches currently occupied by Knowle Football Club;
b) For consistency and clarity purposes all reference to the reprovision/relocation of the Knowle pitches within the policy and supporting text should be modified to playing field site (pitches and ancillary provision)
c) To ensure that the use of the cricket club is not prejudiced by the introduction of residential development adjacent to it the following design principle in line NPPF paragraph 182 should be incorporated into the Policy:
2.IX The provision and maintenance of ball stop mitigation will be required, if deemed necessary following a ball strike risk assessment, and implemented before any ball strike risk is introduced as a result of the proposed development.
d) To enable an identified need within the Council’s Playing Pitch Strategy and Playing Pitch Mitigation Strategy to be met at the site, in accordance with NPPF paragraph 96, provisions within the policy for a 3G pitch should be made within the replacement site.
4.IV The provision for a full sized 3G pitch with sports lighting to be provided at the site.

Policy KN2 entails the relocation of the Arden Academy site. The Academy’s playing field site contains hard court provision, AGP and a number of playing pitches. The Council’s Playing Pitch Strategy identifies that there are current and future shortfalls in playing field provision. The Playing Pitch Strategy identifies that the site is used by the community, which should be formal secured via a community use agreement, and that sports provision should be replaced. In relation to the AGP the Playing Pitch Strategy states that it should replaced by a 3G pitch instead. Given the above the playing field site is not deemed to be surplus to requirement and the policy should ensure the playing field site should not be lost until a replacement provision of equivalent quantity and quality being developed and available for use.
Policy KN2 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
a) To ensure the policy is consistent with NPPF paragraph 97b, as the playing field site incorporating hard court and AGP has not been demonstrated to be surplus to requirement by the Playing Pitch Strategy and utilised by the community, the following modification is proposed to policy KN2:
2. x Development of the Arden Academy Trust playing field site (inclusive of hard court and AGP) and its ancillary facilities shall not commence until the provision of replacement playing field is made available for use. The replacement provision will be at least equivalent or better in terms quantity and quality of that proposed to be lost.
b) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy ME1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO1 identifies that the existing sports pitches are to be retained. Sport England consider that wording sports pitches should be replaced with ‘playing field site’ which is aligned to the wording of NPPF paragraph 97. Further to this the sports pitch layout within a playing field can alter and is not fixed on the site.
Sport England considers this modification is necessary as it would appear that the illustrative concept masterplan for the site has a road which encroaches on to the playing field site reducing the capability of site to accommodate pitches (reducing the size of pitches). No information has been submitted to justify the loss of playing field land in accordance with NPPF paragraph 97/Sport England’s Exception Policies.
Policy SO1 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
A) To ensure the policy wording in relation to the retention of existing playing field site in accordance with NPPF paragraph 97 the following modification is proposed:
V. iii. Retention of existing sports pitch playing field site.
B) For clarity the Concept Illustrative Masterplan should clearly set out there is no encroachment on to the playing field site.
C) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Sport England welcomes the identification of the provision of leisure and community infrastructure though the needs for the site should be informed by a Playing Pitch Strategy and Indoor Needs Assessment. To ensure that the leisure provision and playing pitch demand generated for the site is met the policy/supporting text should make reference to the need to undertake a site specific leisure and playing pitch needs assessment to inform the requirements for the site.

Sport England are supportive of policy UK2 with it ensuring the retention of the existing sports provision site until a suitable alternative site, agreed with Sport England and national governing bodies, being provided and ready for use.

The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy P14 sets out how developments which will cause or be subject to existing
noise, odour or atmospheric pollution, will need to satisfactorily mitigate or abate the identified negative impact on amenity.
The Policy in part covers NPPF paragraph 182 agent of change principle. However, it fails to consider circumstances such as a developments adjacent playing field site for example a cricket club, which could be at risk of ball strike. In such circumstances, in line with NPPF paragraph 182, the development would need to provide mitigation through the provision of ball stop netting to ensure the use of the playing field is not prejudiced or that any unreasonable restrictions are placed on the use of the site.
An additional criterion should be added to Policy P14 to ensure consistency with national planning policy paragraph 182.
* Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed.

Policy P15 could be made more effective in promoting health and well-being, in line with NPPF paragraph 127, by referring to Sport England’s Active Design Guid-ance. The Guidance sets out 10 principles which developments should seek to ad-here to promote activity, health and stronger communities through design.
Active Design is supported by Public Health England and is part of our collabora-tive action to promote the principles set out in Public Health England’s ‘Everybody Active, Every Day’, to create active environments that make physical activity the easiest and most practical option in everyday life.
Add reference to point Policy P15 point 4 to help achieve Objectives F, H and J -
4. All developments should comply with the urban design principles set out in es-tablished current design guidance, including at present; The National Design Guide (2019), Urban Design Compendium 1 and 2 (2007), Manual for Streets 1 (2007) and 2 (2010), Active Design (20015), Building for Life 12 and Secured by Design principles, or their equivalents.

Sport England are supportive of Policy P18 Health and Wellbeing with it containing a number of Active Design Principles which help to promote physical activity.
Sport England considers the policy could be made more effective through the promotion of co-location (the grouping of destinations such as community facilities, schools, shops, work places, sports facilities and leisure centres within close proximity of each other), allowing users to make only one linked trip to an area for multiple reasons. Co-location assists with linked trips reducing the need to travel and allow more time for people to linger and be socially interactive, whilst also creating variety and vitality in town and local centres.
Linked to the above supporting infrastructure should also be promoted such as public conveniences; drinking fountains; cycle, mobility scooter and pushchair storage; changing rooms; quality of seating; Wi-Fi access; shelter and showers. The above are all elements that can influence physical activity choices and should be provided where appropriate to meet the needs of a range of potential users.
Supporting infrastructure to enable sport and physical activity to take place should be provided across all contexts including workplaces, sports facilities and public space, to facilitate all forms of activity.
Provision of new public open space, children’s play, sports and recreational facilities
Point 7 sets out new housing development will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, in line with the minimum standard of 3.57ha per 1,000 population.
The Council’s Playing Pitch Strategy Update and Playing Pitch Mitigation utilises Sport England’s Playing Pitch Demand Calculator Tool to ascertain the playing pitch demand from proposed housing allocations contained within the Plan.
Sport England promotes the use of the calculator with it being informed by a local evidence base document assessment of supply and demand. It is unclear if the standard of 3.57ha per 1,000 population encapsulates playing field provision and if so, how has the figure been justified to identify demand in line with Playing Pitch Strategy and whether it would meet the CIL regulation 122 tests.
Provision of new public open space, children’s play, sports and recreational facilities
Point 9 states new housing developments will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated. It is unclear why the viability caveat is included particularly given Policy P21 and the Plan’s objectives F and J, it might be the circumstances that other contributions should not be sought or that contributions should be proportionality reduced.
Indoor Sports Facilities Strategy 2012

Policy P20 points 10 and 13 refers to an Indoor Sports Facilities Strategy 2012. The document sets out provision standards based on deficit and surpluses for the Borough and then applies these standards to the 2026 projected future population of the Borough. Therefore, the standards proposed and identified deficits/surpluses are not based on robust and up to date assessment of need as there is a failure to consider needs up to 2036.
On the basis of the above the policy (and the IDP) is not consistent with national planning policy with NPPF paragraph 96, which requires planning policies to be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision.
Playing Pitch Strategy
Sport England welcomes the authority undertaking a monitoring and review of its Playing Pitch Strategy 2017. The Playing Pitch Strategy (update) 2019 provides an update on the following inputs amongst others; sites (where informed by national governing bodies and the LPA); team numbers (informed by national governing bodies); strategy period (extending from 2026 to 2036); and site actions.
The update document reaffirms that there are current and future shortfalls in playing field provision within the Borough. Therefore, to ensure demand for pitches are met there is a need to protect existing sites; provide new sites and to improve the quality of the existing sites where identified within the Playing Pitch Strategy Action Plan. The document also provides a robust evidence base to inform the Playing Pitch Mitigation Strategy which establishes the need to replace existing playing field sites proposed for development and identify the playing pitch demands from residential developments. The use of the Playing Pitch Strategy Mitigation report within the site allocations policies contained within the Plan is welcomed and in line with NPPF paragraph 96.
It should be noted dialogue with the LPA as part of the PPS update work confirmed that the authority will conduct a full Playing Pitch Strategy in early 2022, this is supported by Sport England to ensure that authority evidence base remains robust. It should be noted that the authority should still undertake annual reviews in line with Stage E of Sport England’s Playing Pitch Strategy Guidance.
1. The incorporation of the below text within P20 ensures that the demand for playing pitches will be informed/justified by evidence namely the Council’s Playing Pitch Strategy in line with NPPF paragraph 96.
Developer contributions will be required to enhance provision of playing pitch-es, based on additional demand generated by the new residential development and the sufficiency of existing provision to meet current and projected need. The Council will have regard to Sport England’s strategic planning tools and findings of the Playing Pitch Strategy to determine an appropriate amount and type of contribution or provision within new developments.
Where it is agreed by the Council that on-site pitch provision is appropriate to meet identified demand, the applicant is required to provide the new pitch(es) and make provision for its management and maintenance in perpetuity, and clarify these arrangements within a management plan to be agreed by the Council.
2. To ensure that the policy is effective in achieving its objective and policies considerations are not replicated the following amendment is suggested:
New housing developments will be required to provide or contribute to-wards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated.
3. Indoor Sports Facilities Strategy 2012
The authority should commit to updating its Indoor Sports Facilities Strategy 2012 with works commencing prior to the adoption of the Plan to ensure the Plan is consistent with NPPF paragraph 96.

Policy BC2 2. V states the retention of the existing playing field site which is welcomed and in line with the finding of the Playing Pitch Strategy. However, SMBC illustrative concept masterplan appears to display a road abutting the playing field site and the removal of part of a hedgerow which creates a boundary for the playing field site. It is unclear why this has been proposed as it could lead impact on the use of the site such as it being less secure and balls leaving the playing field site.
To ensure that there is reduced impact on the use of playing field the concept masterplan should maintain a strong boundary for the playing field site.
Sport England welcomes the vast majority of the proposed housing allocation policies identifying a need to provide a financial contribution towards the provision of new playing pitches and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy and the Playing Pitch Strategy which identified that there are current and future shortfalls in pitch provision.
However, at this point in time it is unclear as to where the contributions will be directed to with the Plan failing to identify the location or allocation of the new playing pitches/hubs sites.
Further to this on the larger proposed allocation sites (sites which generate the demand for multiple pitches) the illustrative concept masterplans fail to incorporate any on-site playing pitch provision As such there is a possibility that no additional pitches are created which could lead to the deterioration of existing pitches (which already in short supply) due to their use being exacerbated even further.
It should also be noted that ancillary uses such as car parking and changing room facilities will also be required to support the use of playing field sites for formal activities in line with the Playing Pitch Strategy.
Pitch Provision
To ensure the shortfalls identified within the Playing Pitch Strategy is met in accordance with NPPF paragraph 96 the Concept Illustrative Masterplans for sites which create the demand for multi playing pitches should clearly display locations for the pitches and ancillary provision. The need to provide for the pitches will rescind upon such time suitable new off site playing field site(s) have been identified to meet the developments demands for playing field provision. This approach will also assist in ensuring Plan objectives F and J are met.
Ancillary Provision
To ensure that the playing field demand generated from sites in accordance with NPPF paragraph 96 the policy should incorporate the provision of supporting infrastructure required to serve the playing field sites, therefore the below additional text should be incorporated.
v. Financial contribution to provision of new playing pitches (and supporting ancillary provisions) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.
The wording of paragraph 594 should be made clear that the replacement provision should be equivalent or better provision in terms quantity and quality to ensure consistency with NPPF paragraph 97. Further to this new sports provision would also be required to meet the demand generated from the new developments.
In relation to shortlisted replacement sites further details should be provided to ascertain the sites suitability and further clarification is required as to what part of P20 is an enabling policy for replacement pitches and facilities.
For clarity paragraph 594 should be amended as per the below:
Sports and Recreation - Replacement of any lost recreation / sports provision as a result of development will be required to an equivalent or better standard in terms of quantity and quality, including ancillary provision, access and use by the wider community where appropriate. Provision will also be made for playing pitches (and ancillary provision) to meet the demands generated from new developments. Several sites have been shortlisted in the vicinity of the existing clubs West of Dickens Heath, and an enabling policy for replacement pitches and facilities is incorporated within Policy P20

Policy BL1 sets out the existing sports facilities should be retained and remain accessible until such time replacement sites are in place, which is supported by Sport England.
However Policy BL1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To enable the sporting needs from the development are met in line with Playing Pitch Strategy and NPPF paragraph 96 the following change is proposed:
-iii Relocation of the existing sports provision. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Paragraph 605 incorrectly sets out the sports club sites to be relocated with Leafield Athletic FC being retained and Wychall Wanderers FC to be replaced. To ensure clarity as to the site’s to be replaced the following modification is proposed.
605 The larger site is currently occupied by Highgate United FC, Leafield FC Wychall Wanderers FC and Old Yardleians .Rugby Football Club, and re-provision will be required for these sports pitches.

Policy BL2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy BL3 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy HH1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

The allocation of KN1 would entail the relocation of Knowle Football Club within the site on land between the new development and the canal. The policy states that appropriate facilities associated with the provision of outdoor sport will be permitted in the Green Belt, provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
To ensure the current site can be relocated in the area identified within the concept illustrative masterplan, the policy should make clear the replacement entails pitches and ancillary provision (such as floodlighting, clubhouse and car parking). Further to this provisions should be made within the policy to enable the capability of the site containing a 3G pitch in line with recommendations contained within the Council’s Playing Pitch Strategy and the Football Foundations Local Facilities Football Plan to ensure demand in the area can be met.
With regards to the illustrative concept masterplan Sport England and national governing bodies are keen to be engaged with the layout of the replacement site as there are some concerns based on concept such as:
- the introduction of trees within the central areas of the replacement playing field area would reduce the flexibility of the site to be marked out for alternative pitch layouts.
- car parking is detached from the sports pavilion;
- pavilion should be centrally located to the main pitch it seeks to serve
- Pitch orientation should accord with Sport England’s Natural Turf for Sport Guidance which is endorsed by national governing bodies.
- Seek to ensure the provision of sports light and the potential for a 3G pitch is not impacted by the LWS, Listed Buildings or proximity to residential dwellings.
- Cricket pitch should be sited in an area which would be impact by ball strike.
Policy KN1 would result in residential development adjacent an existing cricket club the policy fails to identify this as a principle which should be taken account of within the concept masterplan. The policy should reflect the requirements of NPPF paragraph 182 requiring a ball strike assessment to be undertaken should residential development come forward on the football club site but not on the cricket club site. The findings of the ball strike assessment should be implemented and maintained by the developer (unless of otherwise agreed by the Club following consultation with Sport England and the ECB). It is viewed that this is necessary as the proposed development could be at risk of ball strike which could prejudice the use of the cricket pitch.
a) To ensure replacement provision is equivalent in terms of quantity and quality in line with NPPF paragraph 97 and Sport England Exception Policy E4 the following modification is considered necessary:
viii. Relocation of the existing playing field site (pitches and ancillary provision) sports pitches currently occupied by Knowle Football Club;
b) For consistency and clarity purposes all reference to the reprovision/relocation of the Knowle pitches within the policy and supporting text should be modified to playing field site (pitches and ancillary provision)
c) To ensure that the use of the cricket club is not prejudiced by the introduction of residential development adjacent to it the following design principle in line NPPF paragraph 182 should be incorporated into the Policy:
2.IX The provision and maintenance of ball stop mitigation will be required, if deemed necessary following a ball strike risk assessment, and implemented before any ball strike risk is introduced as a result of the proposed development.
d) To enable an identified need within the Council’s Playing Pitch Strategy and Playing Pitch Mitigation Strategy to be met at the site, in accordance with NPPF paragraph 96, provisions within the policy for a 3G pitch should be made within the replacement site.
4.IV The provision for a full sized 3G pitch with sports lighting to be provided at the site.

Policy KN2 entails the relocation of the Arden Academy site. The Academy’s playing field site contains hard court provision, AGP and a number of playing pitches. The Council’s Playing Pitch Strategy identifies that there are current and future shortfalls in playing field provision. The Playing Pitch Strategy identifies that the site is used by the community, which should be formal secured via a community use agreement, and that sports provision should be replaced. In relation to the AGP the Playing Pitch Strategy states that it should replaced by a 3G pitch instead. Given the above the playing field site is not deemed to be surplus to requirement and the policy should ensure the playing field site should not be lost until a replacement provision of equivalent quantity and quality being developed and available for use.
Policy KN2 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
a) To ensure the policy is consistent with NPPF paragraph 97b, as the playing field site incorporating hard court and AGP has not been demonstrated to be surplus to requirement by the Playing Pitch Strategy and utilised by the community, the following modification is proposed to policy KN2:
2. x Development of the Arden Academy Trust playing field site (inclusive of hard court and AGP) and its ancillary facilities shall not commence until the provision of replacement playing field is made available for use. The replacement provision will be at least equivalent or better in terms quantity and quality of that proposed to be lost.
b) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy ME1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO1 identifies that the existing sports pitches are to be retained. Sport England consider that wording sports pitches should be replaced with ‘playing field site’ which is aligned to the wording of NPPF paragraph 97. Further to this the sports pitch layout within a playing field can alter and is not fixed on the site.
Sport England considers this modification is necessary as it would appear that the illustrative concept masterplan for the site has a road which encroaches on to the playing field site reducing the capability of site to accommodate pitches (reducing the size of pitches). No information has been submitted to justify the loss of playing field land in accordance with NPPF paragraph 97/Sport England’s Exception Policies.
Policy SO1 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
A) To ensure the policy wording in relation to the retention of existing playing field site in accordance with NPPF paragraph 97 the following modification is proposed:
V. iii. Retention of existing sports pitch playing field site.
B) For clarity the Concept Illustrative Masterplan should clearly set out there is no encroachment on to the playing field site.
C) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Sport England welcomes the identification of the provision of leisure and community infrastructure though the needs for the site should be informed by a Playing Pitch Strategy and Indoor Needs Assessment. To ensure that the leisure provision and playing pitch demand generated for the site is met the policy/supporting text should make reference to the need to undertake a site specific leisure and playing pitch needs assessment to inform the requirements for the site.

Sport England are supportive of policy UK2 with it ensuring the retention of the existing sports provision site until a suitable alternative site, agreed with Sport England and national governing bodies, being provided and ready for use.

A) The following modification is proposed:
2 iii. Retention of existing sports pitch playing field site.
B) For clarity the Concept Masterplan should clearly set out there is no encroachment on to the playing field site.
C) The following modification is proposed :
3v Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy P14 sets out how developments which will cause or be subject to existing
noise, odour or atmospheric pollution, will need to satisfactorily mitigate or abate the identified negative impact on amenity.
The Policy in part covers NPPF paragraph 182 agent of change principle. However, it fails to consider circumstances such as a developments adjacent playing field site for example a cricket club, which could be at risk of ball strike. In such circumstances, in line with NPPF paragraph 182, the development would need to provide mitigation through the provision of ball stop netting to ensure the use of the playing field is not prejudiced or that any unreasonable restrictions are placed on the use of the site.
An additional criterion should be added to Policy P14 to ensure consistency with national planning policy paragraph 182.
* Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed.

Policy P15 could be made more effective in promoting health and well-being, in line with NPPF paragraph 127, by referring to Sport England’s Active Design Guid-ance. The Guidance sets out 10 principles which developments should seek to ad-here to promote activity, health and stronger communities through design.
Active Design is supported by Public Health England and is part of our collabora-tive action to promote the principles set out in Public Health England’s ‘Everybody Active, Every Day’, to create active environments that make physical activity the easiest and most practical option in everyday life.
Add reference to point Policy P15 point 4 to help achieve Objectives F, H and J -
4. All developments should comply with the urban design principles set out in es-tablished current design guidance, including at present; The National Design Guide (2019), Urban Design Compendium 1 and 2 (2007), Manual for Streets 1 (2007) and 2 (2010), Active Design (20015), Building for Life 12 and Secured by Design principles, or their equivalents.

Sport England are supportive of Policy P18 Health and Wellbeing with it containing a number of Active Design Principles which help to promote physical activity.
Sport England considers the policy could be made more effective through the promotion of co-location (the grouping of destinations such as community facilities, schools, shops, work places, sports facilities and leisure centres within close proximity of each other), allowing users to make only one linked trip to an area for multiple reasons. Co-location assists with linked trips reducing the need to travel and allow more time for people to linger and be socially interactive, whilst also creating variety and vitality in town and local centres.
Linked to the above supporting infrastructure should also be promoted such as public conveniences; drinking fountains; cycle, mobility scooter and pushchair storage; changing rooms; quality of seating; Wi-Fi access; shelter and showers. The above are all elements that can influence physical activity choices and should be provided where appropriate to meet the needs of a range of potential users.
Supporting infrastructure to enable sport and physical activity to take place should be provided across all contexts including workplaces, sports facilities and public space, to facilitate all forms of activity.
Provision of new public open space, children’s play, sports and recreational facilities
Point 7 sets out new housing development will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, in line with the minimum standard of 3.57ha per 1,000 population.
The Council’s Playing Pitch Strategy Update and Playing Pitch Mitigation utilises Sport England’s Playing Pitch Demand Calculator Tool to ascertain the playing pitch demand from proposed housing allocations contained within the Plan.
Sport England promotes the use of the calculator with it being informed by a local evidence base document assessment of supply and demand. It is unclear if the standard of 3.57ha per 1,000 population encapsulates playing field provision and if so, how has the figure been justified to identify demand in line with Playing Pitch Strategy and whether it would meet the CIL regulation 122 tests.
Provision of new public open space, children’s play, sports and recreational facilities
Point 9 states new housing developments will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated. It is unclear why the viability caveat is included particularly given Policy P21 and the Plan’s objectives F and J, it might be the circumstances that other contributions should not be sought or that contributions should be proportionality reduced.
Indoor Sports Facilities Strategy 2012

Policy P20 points 10 and 13 refers to an Indoor Sports Facilities Strategy 2012. The document sets out provision standards based on deficit and surpluses for the Borough and then applies these standards to the 2026 projected future population of the Borough. Therefore, the standards proposed and identified deficits/surpluses are not based on robust and up to date assessment of need as there is a failure to consider needs up to 2036.
On the basis of the above the policy (and the IDP) is not consistent with national planning policy with NPPF paragraph 96, which requires planning policies to be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision.
Playing Pitch Strategy
Sport England welcomes the authority undertaking a monitoring and review of its Playing Pitch Strategy 2017. The Playing Pitch Strategy (update) 2019 provides an update on the following inputs amongst others; sites (where informed by national governing bodies and the LPA); team numbers (informed by national governing bodies); strategy period (extending from 2026 to 2036); and site actions.
The update document reaffirms that there are current and future shortfalls in playing field provision within the Borough. Therefore, to ensure demand for pitches are met there is a need to protect existing sites; provide new sites and to improve the quality of the existing sites where identified within the Playing Pitch Strategy Action Plan. The document also provides a robust evidence base to inform the Playing Pitch Mitigation Strategy which establishes the need to replace existing playing field sites proposed for development and identify the playing pitch demands from residential developments. The use of the Playing Pitch Strategy Mitigation report within the site allocations policies contained within the Plan is welcomed and in line with NPPF paragraph 96.
It should be noted dialogue with the LPA as part of the PPS update work confirmed that the authority will conduct a full Playing Pitch Strategy in early 2022, this is supported by Sport England to ensure that authority evidence base remains robust. It should be noted that the authority should still undertake annual reviews in line with Stage E of Sport England’s Playing Pitch Strategy Guidance.
1. The incorporation of the below text within P20 ensures that the demand for playing pitches will be informed/justified by evidence namely the Council’s Playing Pitch Strategy in line with NPPF paragraph 96.
Developer contributions will be required to enhance provision of playing pitch-es, based on additional demand generated by the new residential development and the sufficiency of existing provision to meet current and projected need. The Council will have regard to Sport England’s strategic planning tools and findings of the Playing Pitch Strategy to determine an appropriate amount and type of contribution or provision within new developments.
Where it is agreed by the Council that on-site pitch provision is appropriate to meet identified demand, the applicant is required to provide the new pitch(es) and make provision for its management and maintenance in perpetuity, and clarify these arrangements within a management plan to be agreed by the Council.
2. To ensure that the policy is effective in achieving its objective and policies considerations are not replicated the following amendment is suggested:
New housing developments will be required to provide or contribute to-wards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated.
3. Indoor Sports Facilities Strategy 2012
The authority should commit to updating its Indoor Sports Facilities Strategy 2012 with works commencing prior to the adoption of the Plan to ensure the Plan is consistent with NPPF paragraph 96.

Policy BC2 2. V states the retention of the existing playing field site which is welcomed and in line with the finding of the Playing Pitch Strategy. However, SMBC illustrative concept masterplan appears to display a road abutting the playing field site and the removal of part of a hedgerow which creates a boundary for the playing field site. It is unclear why this has been proposed as it could lead impact on the use of the site such as it being less secure and balls leaving the playing field site.
To ensure that there is reduced impact on the use of playing field the concept masterplan should maintain a strong boundary for the playing field site.
Sport England welcomes the vast majority of the proposed housing allocation policies identifying a need to provide a financial contribution towards the provision of new playing pitches and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy and the Playing Pitch Strategy which identified that there are current and future shortfalls in pitch provision.
However, at this point in time it is unclear as to where the contributions will be directed to with the Plan failing to identify the location or allocation of the new playing pitches/hubs sites.
Further to this on the larger proposed allocation sites (sites which generate the demand for multiple pitches) the illustrative concept masterplans fail to incorporate any on-site playing pitch provision As such there is a possibility that no additional pitches are created which could lead to the deterioration of existing pitches (which already in short supply) due to their use being exacerbated even further.
It should also be noted that ancillary uses such as car parking and changing room facilities will also be required to support the use of playing field sites for formal activities in line with the Playing Pitch Strategy.
Pitch Provision
To ensure the shortfalls identified within the Playing Pitch Strategy is met in accordance with NPPF paragraph 96 the Concept Illustrative Masterplans for sites which create the demand for multi playing pitches should clearly display locations for the pitches and ancillary provision. The need to provide for the pitches will rescind upon such time suitable new off site playing field site(s) have been identified to meet the developments demands for playing field provision. This approach will also assist in ensuring Plan objectives F and J are met.
Ancillary Provision
To ensure that the playing field demand generated from sites in accordance with NPPF paragraph 96 the policy should incorporate the provision of supporting infrastructure required to serve the playing field sites, therefore the below additional text should be incorporated.
v. Financial contribution to provision of new playing pitches (and supporting ancillary provisions) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.
The wording of paragraph 594 should be made clear that the replacement provision should be equivalent or better provision in terms quantity and quality to ensure consistency with NPPF paragraph 97. Further to this new sports provision would also be required to meet the demand generated from the new developments.
In relation to shortlisted replacement sites further details should be provided to ascertain the sites suitability and further clarification is required as to what part of P20 is an enabling policy for replacement pitches and facilities.
For clarity paragraph 594 should be amended as per the below:
Sports and Recreation - Replacement of any lost recreation / sports provision as a result of development will be required to an equivalent or better standard in terms of quantity and quality, including ancillary provision, access and use by the wider community where appropriate. Provision will also be made for playing pitches (and ancillary provision) to meet the demands generated from new developments. Several sites have been shortlisted in the vicinity of the existing clubs West of Dickens Heath, and an enabling policy for replacement pitches and facilities is incorporated within Policy P20

Policy BL1 sets out the existing sports facilities should be retained and remain accessible until such time replacement sites are in place, which is supported by Sport England.
However Policy BL1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To enable the sporting needs from the development are met in line with Playing Pitch Strategy and NPPF paragraph 96 the following change is proposed:
-iii Relocation of the existing sports provision. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Paragraph 605 incorrectly sets out the sports club sites to be relocated with Leafield Athletic FC being retained and Wychall Wanderers FC to be replaced. To ensure clarity as to the site’s to be replaced the following modification is proposed.
605 The larger site is currently occupied by Highgate United FC, Leafield FC Wychall Wanderers FC and Old Yardleians .Rugby Football Club, and re-provision will be required for these sports pitches.

Policy BL2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy BL3 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy HH1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

The allocation of KN1 would entail the relocation of Knowle Football Club within the site on land between the new development and the canal. The policy states that appropriate facilities associated with the provision of outdoor sport will be permitted in the Green Belt, provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
To ensure the current site can be relocated in the area identified within the concept illustrative masterplan, the policy should make clear the replacement entails pitches and ancillary provision (such as floodlighting, clubhouse and car parking). Further to this provisions should be made within the policy to enable the capability of the site containing a 3G pitch in line with recommendations contained within the Council’s Playing Pitch Strategy and the Football Foundations Local Facilities Football Plan to ensure demand in the area can be met.
With regards to the illustrative concept masterplan Sport England and national governing bodies are keen to be engaged with the layout of the replacement site as there are some concerns based on concept such as:
- the introduction of trees within the central areas of the replacement playing field area would reduce the flexibility of the site to be marked out for alternative pitch layouts.
- car parking is detached from the sports pavilion;
- pavilion should be centrally located to the main pitch it seeks to serve
- Pitch orientation should accord with Sport England’s Natural Turf for Sport Guidance which is endorsed by national governing bodies.
- Seek to ensure the provision of sports light and the potential for a 3G pitch is not impacted by the LWS, Listed Buildings or proximity to residential dwellings.
- Cricket pitch should be sited in an area which would be impact by ball strike.
Policy KN1 would result in residential development adjacent an existing cricket club the policy fails to identify this as a principle which should be taken account of within the concept masterplan. The policy should reflect the requirements of NPPF paragraph 182 requiring a ball strike assessment to be undertaken should residential development come forward on the football club site but not on the cricket club site. The findings of the ball strike assessment should be implemented and maintained by the developer (unless of otherwise agreed by the Club following consultation with Sport England and the ECB). It is viewed that this is necessary as the proposed development could be at risk of ball strike which could prejudice the use of the cricket pitch.
a) To ensure replacement provision is equivalent in terms of quantity and quality in line with NPPF paragraph 97 and Sport England Exception Policy E4 the following modification is considered necessary:
viii. Relocation of the existing playing field site (pitches and ancillary provision) sports pitches currently occupied by Knowle Football Club;
b) For consistency and clarity purposes all reference to the reprovision/relocation of the Knowle pitches within the policy and supporting text should be modified to playing field site (pitches and ancillary provision)
c) To ensure that the use of the cricket club is not prejudiced by the introduction of residential development adjacent to it the following design principle in line NPPF paragraph 182 should be incorporated into the Policy:
2.IX The provision and maintenance of ball stop mitigation will be required, if deemed necessary following a ball strike risk assessment, and implemented before any ball strike risk is introduced as a result of the proposed development.
d) To enable an identified need within the Council’s Playing Pitch Strategy and Playing Pitch Mitigation Strategy to be met at the site, in accordance with NPPF paragraph 96, provisions within the policy for a 3G pitch should be made within the replacement site.
4.IV The provision for a full sized 3G pitch with sports lighting to be provided at the site.

Policy KN2 entails the relocation of the Arden Academy site. The Academy’s playing field site contains hard court provision, AGP and a number of playing pitches. The Council’s Playing Pitch Strategy identifies that there are current and future shortfalls in playing field provision. The Playing Pitch Strategy identifies that the site is used by the community, which should be formal secured via a community use agreement, and that sports provision should be replaced. In relation to the AGP the Playing Pitch Strategy states that it should replaced by a 3G pitch instead. Given the above the playing field site is not deemed to be surplus to requirement and the policy should ensure the playing field site should not be lost until a replacement provision of equivalent quantity and quality being developed and available for use.
Policy KN2 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
a) To ensure the policy is consistent with NPPF paragraph 97b, as the playing field site incorporating hard court and AGP has not been demonstrated to be surplus to requirement by the Playing Pitch Strategy and utilised by the community, the following modification is proposed to policy KN2:
2. x Development of the Arden Academy Trust playing field site (inclusive of hard court and AGP) and its ancillary facilities shall not commence until the provision of replacement playing field is made available for use. The replacement provision will be at least equivalent or better in terms quantity and quality of that proposed to be lost.
b) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy ME1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO1 identifies that the existing sports pitches are to be retained. Sport England consider that wording sports pitches should be replaced with ‘playing field site’ which is aligned to the wording of NPPF paragraph 97. Further to this the sports pitch layout within a playing field can alter and is not fixed on the site.
Sport England considers this modification is necessary as it would appear that the illustrative concept masterplan for the site has a road which encroaches on to the playing field site reducing the capability of site to accommodate pitches (reducing the size of pitches). No information has been submitted to justify the loss of playing field land in accordance with NPPF paragraph 97/Sport England’s Exception Policies.
Policy SO1 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
A) To ensure the policy wording in relation to the retention of existing playing field site in accordance with NPPF paragraph 97 the following modification is proposed:
V. iii. Retention of existing sports pitch playing field site.
B) For clarity the Concept Illustrative Masterplan should clearly set out there is no encroachment on to the playing field site.
C) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Sport England welcomes the identification of the provision of leisure and community infrastructure though the needs for the site should be informed by a Playing Pitch Strategy and Indoor Needs Assessment. To ensure that the leisure provision and playing pitch demand generated for the site is met the policy/supporting text should make reference to the need to undertake a site specific leisure and playing pitch needs assessment to inform the requirements for the site.

Sport England are supportive of policy UK2 with it ensuring the retention of the existing sports provision site until a suitable alternative site, agreed with Sport England and national governing bodies, being provided and ready for use.

To ensure that the leisure provision and playing pitch demand generated for the site is met the policy/supporting text should make reference to the need to undertake a site specific leisure and playing pitch needs assessment to inform the requirements for the site.

Policy P14 sets out how developments which will cause or be subject to existing
noise, odour or atmospheric pollution, will need to satisfactorily mitigate or abate the identified negative impact on amenity.
The Policy in part covers NPPF paragraph 182 agent of change principle. However, it fails to consider circumstances such as a developments adjacent playing field site for example a cricket club, which could be at risk of ball strike. In such circumstances, in line with NPPF paragraph 182, the development would need to provide mitigation through the provision of ball stop netting to ensure the use of the playing field is not prejudiced or that any unreasonable restrictions are placed on the use of the site.
An additional criterion should be added to Policy P14 to ensure consistency with national planning policy paragraph 182.
* Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed.

Policy P15 could be made more effective in promoting health and well-being, in line with NPPF paragraph 127, by referring to Sport England’s Active Design Guid-ance. The Guidance sets out 10 principles which developments should seek to ad-here to promote activity, health and stronger communities through design.
Active Design is supported by Public Health England and is part of our collabora-tive action to promote the principles set out in Public Health England’s ‘Everybody Active, Every Day’, to create active environments that make physical activity the easiest and most practical option in everyday life.
Add reference to point Policy P15 point 4 to help achieve Objectives F, H and J -
4. All developments should comply with the urban design principles set out in es-tablished current design guidance, including at present; The National Design Guide (2019), Urban Design Compendium 1 and 2 (2007), Manual for Streets 1 (2007) and 2 (2010), Active Design (20015), Building for Life 12 and Secured by Design principles, or their equivalents.

Sport England are supportive of Policy P18 Health and Wellbeing with it containing a number of Active Design Principles which help to promote physical activity.
Sport England considers the policy could be made more effective through the promotion of co-location (the grouping of destinations such as community facilities, schools, shops, work places, sports facilities and leisure centres within close proximity of each other), allowing users to make only one linked trip to an area for multiple reasons. Co-location assists with linked trips reducing the need to travel and allow more time for people to linger and be socially interactive, whilst also creating variety and vitality in town and local centres.
Linked to the above supporting infrastructure should also be promoted such as public conveniences; drinking fountains; cycle, mobility scooter and pushchair storage; changing rooms; quality of seating; Wi-Fi access; shelter and showers. The above are all elements that can influence physical activity choices and should be provided where appropriate to meet the needs of a range of potential users.
Supporting infrastructure to enable sport and physical activity to take place should be provided across all contexts including workplaces, sports facilities and public space, to facilitate all forms of activity.
Provision of new public open space, children’s play, sports and recreational facilities
Point 7 sets out new housing development will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, in line with the minimum standard of 3.57ha per 1,000 population.
The Council’s Playing Pitch Strategy Update and Playing Pitch Mitigation utilises Sport England’s Playing Pitch Demand Calculator Tool to ascertain the playing pitch demand from proposed housing allocations contained within the Plan.
Sport England promotes the use of the calculator with it being informed by a local evidence base document assessment of supply and demand. It is unclear if the standard of 3.57ha per 1,000 population encapsulates playing field provision and if so, how has the figure been justified to identify demand in line with Playing Pitch Strategy and whether it would meet the CIL regulation 122 tests.
Provision of new public open space, children’s play, sports and recreational facilities
Point 9 states new housing developments will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated. It is unclear why the viability caveat is included particularly given Policy P21 and the Plan’s objectives F and J, it might be the circumstances that other contributions should not be sought or that contributions should be proportionality reduced.
Indoor Sports Facilities Strategy 2012

Policy P20 points 10 and 13 refers to an Indoor Sports Facilities Strategy 2012. The document sets out provision standards based on deficit and surpluses for the Borough and then applies these standards to the 2026 projected future population of the Borough. Therefore, the standards proposed and identified deficits/surpluses are not based on robust and up to date assessment of need as there is a failure to consider needs up to 2036.
On the basis of the above the policy (and the IDP) is not consistent with national planning policy with NPPF paragraph 96, which requires planning policies to be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision.
Playing Pitch Strategy
Sport England welcomes the authority undertaking a monitoring and review of its Playing Pitch Strategy 2017. The Playing Pitch Strategy (update) 2019 provides an update on the following inputs amongst others; sites (where informed by national governing bodies and the LPA); team numbers (informed by national governing bodies); strategy period (extending from 2026 to 2036); and site actions.
The update document reaffirms that there are current and future shortfalls in playing field provision within the Borough. Therefore, to ensure demand for pitches are met there is a need to protect existing sites; provide new sites and to improve the quality of the existing sites where identified within the Playing Pitch Strategy Action Plan. The document also provides a robust evidence base to inform the Playing Pitch Mitigation Strategy which establishes the need to replace existing playing field sites proposed for development and identify the playing pitch demands from residential developments. The use of the Playing Pitch Strategy Mitigation report within the site allocations policies contained within the Plan is welcomed and in line with NPPF paragraph 96.
It should be noted dialogue with the LPA as part of the PPS update work confirmed that the authority will conduct a full Playing Pitch Strategy in early 2022, this is supported by Sport England to ensure that authority evidence base remains robust. It should be noted that the authority should still undertake annual reviews in line with Stage E of Sport England’s Playing Pitch Strategy Guidance.
1. The incorporation of the below text within P20 ensures that the demand for playing pitches will be informed/justified by evidence namely the Council’s Playing Pitch Strategy in line with NPPF paragraph 96.
Developer contributions will be required to enhance provision of playing pitch-es, based on additional demand generated by the new residential development and the sufficiency of existing provision to meet current and projected need. The Council will have regard to Sport England’s strategic planning tools and findings of the Playing Pitch Strategy to determine an appropriate amount and type of contribution or provision within new developments.
Where it is agreed by the Council that on-site pitch provision is appropriate to meet identified demand, the applicant is required to provide the new pitch(es) and make provision for its management and maintenance in perpetuity, and clarify these arrangements within a management plan to be agreed by the Council.
2. To ensure that the policy is effective in achieving its objective and policies considerations are not replicated the following amendment is suggested:
New housing developments will be required to provide or contribute to-wards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated.
3. Indoor Sports Facilities Strategy 2012
The authority should commit to updating its Indoor Sports Facilities Strategy 2012 with works commencing prior to the adoption of the Plan to ensure the Plan is consistent with NPPF paragraph 96.

Policy BC2 2. V states the retention of the existing playing field site which is welcomed and in line with the finding of the Playing Pitch Strategy. However, SMBC illustrative concept masterplan appears to display a road abutting the playing field site and the removal of part of a hedgerow which creates a boundary for the playing field site. It is unclear why this has been proposed as it could lead impact on the use of the site such as it being less secure and balls leaving the playing field site.
To ensure that there is reduced impact on the use of playing field the concept masterplan should maintain a strong boundary for the playing field site.
Sport England welcomes the vast majority of the proposed housing allocation policies identifying a need to provide a financial contribution towards the provision of new playing pitches and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy and the Playing Pitch Strategy which identified that there are current and future shortfalls in pitch provision.
However, at this point in time it is unclear as to where the contributions will be directed to with the Plan failing to identify the location or allocation of the new playing pitches/hubs sites.
Further to this on the larger proposed allocation sites (sites which generate the demand for multiple pitches) the illustrative concept masterplans fail to incorporate any on-site playing pitch provision As such there is a possibility that no additional pitches are created which could lead to the deterioration of existing pitches (which already in short supply) due to their use being exacerbated even further.
It should also be noted that ancillary uses such as car parking and changing room facilities will also be required to support the use of playing field sites for formal activities in line with the Playing Pitch Strategy.
Pitch Provision
To ensure the shortfalls identified within the Playing Pitch Strategy is met in accordance with NPPF paragraph 96 the Concept Illustrative Masterplans for sites which create the demand for multi playing pitches should clearly display locations for the pitches and ancillary provision. The need to provide for the pitches will rescind upon such time suitable new off site playing field site(s) have been identified to meet the developments demands for playing field provision. This approach will also assist in ensuring Plan objectives F and J are met.
Ancillary Provision
To ensure that the playing field demand generated from sites in accordance with NPPF paragraph 96 the policy should incorporate the provision of supporting infrastructure required to serve the playing field sites, therefore the below additional text should be incorporated.
v. Financial contribution to provision of new playing pitches (and supporting ancillary provisions) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.
The wording of paragraph 594 should be made clear that the replacement provision should be equivalent or better provision in terms quantity and quality to ensure consistency with NPPF paragraph 97. Further to this new sports provision would also be required to meet the demand generated from the new developments.
In relation to shortlisted replacement sites further details should be provided to ascertain the sites suitability and further clarification is required as to what part of P20 is an enabling policy for replacement pitches and facilities.
For clarity paragraph 594 should be amended as per the below:
Sports and Recreation - Replacement of any lost recreation / sports provision as a result of development will be required to an equivalent or better standard in terms of quantity and quality, including ancillary provision, access and use by the wider community where appropriate. Provision will also be made for playing pitches (and ancillary provision) to meet the demands generated from new developments. Several sites have been shortlisted in the vicinity of the existing clubs West of Dickens Heath, and an enabling policy for replacement pitches and facilities is incorporated within Policy P20

Policy BL1 sets out the existing sports facilities should be retained and remain accessible until such time replacement sites are in place, which is supported by Sport England.
However Policy BL1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To enable the sporting needs from the development are met in line with Playing Pitch Strategy and NPPF paragraph 96 the following change is proposed:
-iii Relocation of the existing sports provision. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Paragraph 605 incorrectly sets out the sports club sites to be relocated with Leafield Athletic FC being retained and Wychall Wanderers FC to be replaced. To ensure clarity as to the site’s to be replaced the following modification is proposed.
605 The larger site is currently occupied by Highgate United FC, Leafield FC Wychall Wanderers FC and Old Yardleians .Rugby Football Club, and re-provision will be required for these sports pitches.

Policy BL2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy BL3 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy HH1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

The allocation of KN1 would entail the relocation of Knowle Football Club within the site on land between the new development and the canal. The policy states that appropriate facilities associated with the provision of outdoor sport will be permitted in the Green Belt, provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
To ensure the current site can be relocated in the area identified within the concept illustrative masterplan, the policy should make clear the replacement entails pitches and ancillary provision (such as floodlighting, clubhouse and car parking). Further to this provisions should be made within the policy to enable the capability of the site containing a 3G pitch in line with recommendations contained within the Council’s Playing Pitch Strategy and the Football Foundations Local Facilities Football Plan to ensure demand in the area can be met.
With regards to the illustrative concept masterplan Sport England and national governing bodies are keen to be engaged with the layout of the replacement site as there are some concerns based on concept such as:
- the introduction of trees within the central areas of the replacement playing field area would reduce the flexibility of the site to be marked out for alternative pitch layouts.
- car parking is detached from the sports pavilion;
- pavilion should be centrally located to the main pitch it seeks to serve
- Pitch orientation should accord with Sport England’s Natural Turf for Sport Guidance which is endorsed by national governing bodies.
- Seek to ensure the provision of sports light and the potential for a 3G pitch is not impacted by the LWS, Listed Buildings or proximity to residential dwellings.
- Cricket pitch should be sited in an area which would be impact by ball strike.
Policy KN1 would result in residential development adjacent an existing cricket club the policy fails to identify this as a principle which should be taken account of within the concept masterplan. The policy should reflect the requirements of NPPF paragraph 182 requiring a ball strike assessment to be undertaken should residential development come forward on the football club site but not on the cricket club site. The findings of the ball strike assessment should be implemented and maintained by the developer (unless of otherwise agreed by the Club following consultation with Sport England and the ECB). It is viewed that this is necessary as the proposed development could be at risk of ball strike which could prejudice the use of the cricket pitch.
a) To ensure replacement provision is equivalent in terms of quantity and quality in line with NPPF paragraph 97 and Sport England Exception Policy E4 the following modification is considered necessary:
viii. Relocation of the existing playing field site (pitches and ancillary provision) sports pitches currently occupied by Knowle Football Club;
b) For consistency and clarity purposes all reference to the reprovision/relocation of the Knowle pitches within the policy and supporting text should be modified to playing field site (pitches and ancillary provision)
c) To ensure that the use of the cricket club is not prejudiced by the introduction of residential development adjacent to it the following design principle in line NPPF paragraph 182 should be incorporated into the Policy:
2.IX The provision and maintenance of ball stop mitigation will be required, if deemed necessary following a ball strike risk assessment, and implemented before any ball strike risk is introduced as a result of the proposed development.
d) To enable an identified need within the Council’s Playing Pitch Strategy and Playing Pitch Mitigation Strategy to be met at the site, in accordance with NPPF paragraph 96, provisions within the policy for a 3G pitch should be made within the replacement site.
4.IV The provision for a full sized 3G pitch with sports lighting to be provided at the site.

Policy KN2 entails the relocation of the Arden Academy site. The Academy’s playing field site contains hard court provision, AGP and a number of playing pitches. The Council’s Playing Pitch Strategy identifies that there are current and future shortfalls in playing field provision. The Playing Pitch Strategy identifies that the site is used by the community, which should be formal secured via a community use agreement, and that sports provision should be replaced. In relation to the AGP the Playing Pitch Strategy states that it should replaced by a 3G pitch instead. Given the above the playing field site is not deemed to be surplus to requirement and the policy should ensure the playing field site should not be lost until a replacement provision of equivalent quantity and quality being developed and available for use.
Policy KN2 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
a) To ensure the policy is consistent with NPPF paragraph 97b, as the playing field site incorporating hard court and AGP has not been demonstrated to be surplus to requirement by the Playing Pitch Strategy and utilised by the community, the following modification is proposed to policy KN2:
2. x Development of the Arden Academy Trust playing field site (inclusive of hard court and AGP) and its ancillary facilities shall not commence until the provision of replacement playing field is made available for use. The replacement provision will be at least equivalent or better in terms quantity and quality of that proposed to be lost.
b) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy ME1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO1 identifies that the existing sports pitches are to be retained. Sport England consider that wording sports pitches should be replaced with ‘playing field site’ which is aligned to the wording of NPPF paragraph 97. Further to this the sports pitch layout within a playing field can alter and is not fixed on the site.
Sport England considers this modification is necessary as it would appear that the illustrative concept masterplan for the site has a road which encroaches on to the playing field site reducing the capability of site to accommodate pitches (reducing the size of pitches). No information has been submitted to justify the loss of playing field land in accordance with NPPF paragraph 97/Sport England’s Exception Policies.
Policy SO1 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
A) To ensure the policy wording in relation to the retention of existing playing field site in accordance with NPPF paragraph 97 the following modification is proposed:
V. iii. Retention of existing sports pitch playing field site.
B) For clarity the Concept Illustrative Masterplan should clearly set out there is no encroachment on to the playing field site.
C) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Sport England welcomes the identification of the provision of leisure and community infrastructure though the needs for the site should be informed by a Playing Pitch Strategy and Indoor Needs Assessment. To ensure that the leisure provision and playing pitch demand generated for the site is met the policy/supporting text should make reference to the need to undertake a site specific leisure and playing pitch needs assessment to inform the requirements for the site.

Sport England are supportive of policy UK2 with it ensuring the retention of the existing sports provision site until a suitable alternative site, agreed with Sport England and national governing bodies, being provided and ready for use.

Policy P14 sets out how developments which will cause or be subject to existing
noise, odour or atmospheric pollution, will need to satisfactorily mitigate or abate the identified negative impact on amenity.
The Policy in part covers NPPF paragraph 182 agent of change principle. However, it fails to consider circumstances such as a developments adjacent playing field site for example a cricket club, which could be at risk of ball strike. In such circumstances, in line with NPPF paragraph 182, the development would need to provide mitigation through the provision of ball stop netting to ensure the use of the playing field is not prejudiced or that any unreasonable restrictions are placed on the use of the site.
An additional criterion should be added to Policy P14 to ensure consistency with national planning policy paragraph 182.
* Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed.

Policy P15 could be made more effective in promoting health and well-being, in line with NPPF paragraph 127, by referring to Sport England’s Active Design Guid-ance. The Guidance sets out 10 principles which developments should seek to ad-here to promote activity, health and stronger communities through design.
Active Design is supported by Public Health England and is part of our collabora-tive action to promote the principles set out in Public Health England’s ‘Everybody Active, Every Day’, to create active environments that make physical activity the easiest and most practical option in everyday life.
Add reference to point Policy P15 point 4 to help achieve Objectives F, H and J -
4. All developments should comply with the urban design principles set out in es-tablished current design guidance, including at present; The National Design Guide (2019), Urban Design Compendium 1 and 2 (2007), Manual for Streets 1 (2007) and 2 (2010), Active Design (20015), Building for Life 12 and Secured by Design principles, or their equivalents.

Sport England are supportive of Policy P18 Health and Wellbeing with it containing a number of Active Design Principles which help to promote physical activity.
Sport England considers the policy could be made more effective through the promotion of co-location (the grouping of destinations such as community facilities, schools, shops, work places, sports facilities and leisure centres within close proximity of each other), allowing users to make only one linked trip to an area for multiple reasons. Co-location assists with linked trips reducing the need to travel and allow more time for people to linger and be socially interactive, whilst also creating variety and vitality in town and local centres.
Linked to the above supporting infrastructure should also be promoted such as public conveniences; drinking fountains; cycle, mobility scooter and pushchair storage; changing rooms; quality of seating; Wi-Fi access; shelter and showers. The above are all elements that can influence physical activity choices and should be provided where appropriate to meet the needs of a range of potential users.
Supporting infrastructure to enable sport and physical activity to take place should be provided across all contexts including workplaces, sports facilities and public space, to facilitate all forms of activity.
Provision of new public open space, children’s play, sports and recreational facilities
Point 7 sets out new housing development will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, in line with the minimum standard of 3.57ha per 1,000 population.
The Council’s Playing Pitch Strategy Update and Playing Pitch Mitigation utilises Sport England’s Playing Pitch Demand Calculator Tool to ascertain the playing pitch demand from proposed housing allocations contained within the Plan.
Sport England promotes the use of the calculator with it being informed by a local evidence base document assessment of supply and demand. It is unclear if the standard of 3.57ha per 1,000 population encapsulates playing field provision and if so, how has the figure been justified to identify demand in line with Playing Pitch Strategy and whether it would meet the CIL regulation 122 tests.
Provision of new public open space, children’s play, sports and recreational facilities
Point 9 states new housing developments will be required to provide or contribute towards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated. It is unclear why the viability caveat is included particularly given Policy P21 and the Plan’s objectives F and J, it might be the circumstances that other contributions should not be sought or that contributions should be proportionality reduced.
Indoor Sports Facilities Strategy 2012

Policy P20 points 10 and 13 refers to an Indoor Sports Facilities Strategy 2012. The document sets out provision standards based on deficit and surpluses for the Borough and then applies these standards to the 2026 projected future population of the Borough. Therefore, the standards proposed and identified deficits/surpluses are not based on robust and up to date assessment of need as there is a failure to consider needs up to 2036.
On the basis of the above the policy (and the IDP) is not consistent with national planning policy with NPPF paragraph 96, which requires planning policies to be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision.
Playing Pitch Strategy
Sport England welcomes the authority undertaking a monitoring and review of its Playing Pitch Strategy 2017. The Playing Pitch Strategy (update) 2019 provides an update on the following inputs amongst others; sites (where informed by national governing bodies and the LPA); team numbers (informed by national governing bodies); strategy period (extending from 2026 to 2036); and site actions.
The update document reaffirms that there are current and future shortfalls in playing field provision within the Borough. Therefore, to ensure demand for pitches are met there is a need to protect existing sites; provide new sites and to improve the quality of the existing sites where identified within the Playing Pitch Strategy Action Plan. The document also provides a robust evidence base to inform the Playing Pitch Mitigation Strategy which establishes the need to replace existing playing field sites proposed for development and identify the playing pitch demands from residential developments. The use of the Playing Pitch Strategy Mitigation report within the site allocations policies contained within the Plan is welcomed and in line with NPPF paragraph 96.
It should be noted dialogue with the LPA as part of the PPS update work confirmed that the authority will conduct a full Playing Pitch Strategy in early 2022, this is supported by Sport England to ensure that authority evidence base remains robust. It should be noted that the authority should still undertake annual reviews in line with Stage E of Sport England’s Playing Pitch Strategy Guidance.
1. The incorporation of the below text within P20 ensures that the demand for playing pitches will be informed/justified by evidence namely the Council’s Playing Pitch Strategy in line with NPPF paragraph 96.
Developer contributions will be required to enhance provision of playing pitch-es, based on additional demand generated by the new residential development and the sufficiency of existing provision to meet current and projected need. The Council will have regard to Sport England’s strategic planning tools and findings of the Playing Pitch Strategy to determine an appropriate amount and type of contribution or provision within new developments.
Where it is agreed by the Council that on-site pitch provision is appropriate to meet identified demand, the applicant is required to provide the new pitch(es) and make provision for its management and maintenance in perpetuity, and clarify these arrangements within a management plan to be agreed by the Council.
2. To ensure that the policy is effective in achieving its objective and policies considerations are not replicated the following amendment is suggested:
New housing developments will be required to provide or contribute to-wards new open spaces or the improvement of existing provision in the area, unless financial unviability is clearly demonstrated.
3. Indoor Sports Facilities Strategy 2012
The authority should commit to updating its Indoor Sports Facilities Strategy 2012 with works commencing prior to the adoption of the Plan to ensure the Plan is consistent with NPPF paragraph 96.

Policy BC2 2. V states the retention of the existing playing field site which is welcomed and in line with the finding of the Playing Pitch Strategy. However, SMBC illustrative concept masterplan appears to display a road abutting the playing field site and the removal of part of a hedgerow which creates a boundary for the playing field site. It is unclear why this has been proposed as it could lead impact on the use of the site such as it being less secure and balls leaving the playing field site.
To ensure that there is reduced impact on the use of playing field the concept masterplan should maintain a strong boundary for the playing field site.
Sport England welcomes the vast majority of the proposed housing allocation policies identifying a need to provide a financial contribution towards the provision of new playing pitches and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy and the Playing Pitch Strategy which identified that there are current and future shortfalls in pitch provision.
However, at this point in time it is unclear as to where the contributions will be directed to with the Plan failing to identify the location or allocation of the new playing pitches/hubs sites.
Further to this on the larger proposed allocation sites (sites which generate the demand for multiple pitches) the illustrative concept masterplans fail to incorporate any on-site playing pitch provision As such there is a possibility that no additional pitches are created which could lead to the deterioration of existing pitches (which already in short supply) due to their use being exacerbated even further.
It should also be noted that ancillary uses such as car parking and changing room facilities will also be required to support the use of playing field sites for formal activities in line with the Playing Pitch Strategy.
Pitch Provision
To ensure the shortfalls identified within the Playing Pitch Strategy is met in accordance with NPPF paragraph 96 the Concept Illustrative Masterplans for sites which create the demand for multi playing pitches should clearly display locations for the pitches and ancillary provision. The need to provide for the pitches will rescind upon such time suitable new off site playing field site(s) have been identified to meet the developments demands for playing field provision. This approach will also assist in ensuring Plan objectives F and J are met.
Ancillary Provision
To ensure that the playing field demand generated from sites in accordance with NPPF paragraph 96 the policy should incorporate the provision of supporting infrastructure required to serve the playing field sites, therefore the below additional text should be incorporated.
v. Financial contribution to provision of new playing pitches (and supporting ancillary provisions) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.
The wording of paragraph 594 should be made clear that the replacement provision should be equivalent or better provision in terms quantity and quality to ensure consistency with NPPF paragraph 97. Further to this new sports provision would also be required to meet the demand generated from the new developments.
In relation to shortlisted replacement sites further details should be provided to ascertain the sites suitability and further clarification is required as to what part of P20 is an enabling policy for replacement pitches and facilities.
For clarity paragraph 594 should be amended as per the below:
Sports and Recreation - Replacement of any lost recreation / sports provision as a result of development will be required to an equivalent or better standard in terms of quantity and quality, including ancillary provision, access and use by the wider community where appropriate. Provision will also be made for playing pitches (and ancillary provision) to meet the demands generated from new developments. Several sites have been shortlisted in the vicinity of the existing clubs West of Dickens Heath, and an enabling policy for replacement pitches and facilities is incorporated within Policy P20

Policy BL1 sets out the existing sports facilities should be retained and remain accessible until such time replacement sites are in place, which is supported by Sport England.
However Policy BL1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To enable the sporting needs from the development are met in line with Playing Pitch Strategy and NPPF paragraph 96 the following change is proposed:
-iii Relocation of the existing sports provision. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Paragraph 605 incorrectly sets out the sports club sites to be relocated with Leafield Athletic FC being retained and Wychall Wanderers FC to be replaced. To ensure clarity as to the site’s to be replaced the following modification is proposed.
605 The larger site is currently occupied by Highgate United FC, Leafield FC Wychall Wanderers FC and Old Yardleians .Rugby Football Club, and re-provision will be required for these sports pitches.

Policy BL2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy BL3 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy HH1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

The allocation of KN1 would entail the relocation of Knowle Football Club within the site on land between the new development and the canal. The policy states that appropriate facilities associated with the provision of outdoor sport will be permitted in the Green Belt, provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.
To ensure the current site can be relocated in the area identified within the concept illustrative masterplan, the policy should make clear the replacement entails pitches and ancillary provision (such as floodlighting, clubhouse and car parking). Further to this provisions should be made within the policy to enable the capability of the site containing a 3G pitch in line with recommendations contained within the Council’s Playing Pitch Strategy and the Football Foundations Local Facilities Football Plan to ensure demand in the area can be met.
With regards to the illustrative concept masterplan Sport England and national governing bodies are keen to be engaged with the layout of the replacement site as there are some concerns based on concept such as:
- the introduction of trees within the central areas of the replacement playing field area would reduce the flexibility of the site to be marked out for alternative pitch layouts.
- car parking is detached from the sports pavilion;
- pavilion should be centrally located to the main pitch it seeks to serve
- Pitch orientation should accord with Sport England’s Natural Turf for Sport Guidance which is endorsed by national governing bodies.
- Seek to ensure the provision of sports light and the potential for a 3G pitch is not impacted by the LWS, Listed Buildings or proximity to residential dwellings.
- Cricket pitch should be sited in an area which would be impact by ball strike.
Policy KN1 would result in residential development adjacent an existing cricket club the policy fails to identify this as a principle which should be taken account of within the concept masterplan. The policy should reflect the requirements of NPPF paragraph 182 requiring a ball strike assessment to be undertaken should residential development come forward on the football club site but not on the cricket club site. The findings of the ball strike assessment should be implemented and maintained by the developer (unless of otherwise agreed by the Club following consultation with Sport England and the ECB). It is viewed that this is necessary as the proposed development could be at risk of ball strike which could prejudice the use of the cricket pitch.
a) To ensure replacement provision is equivalent in terms of quantity and quality in line with NPPF paragraph 97 and Sport England Exception Policy E4 the following modification is considered necessary:
viii. Relocation of the existing playing field site (pitches and ancillary provision) sports pitches currently occupied by Knowle Football Club;
b) For consistency and clarity purposes all reference to the reprovision/relocation of the Knowle pitches within the policy and supporting text should be modified to playing field site (pitches and ancillary provision)
c) To ensure that the use of the cricket club is not prejudiced by the introduction of residential development adjacent to it the following design principle in line NPPF paragraph 182 should be incorporated into the Policy:
2.IX The provision and maintenance of ball stop mitigation will be required, if deemed necessary following a ball strike risk assessment, and implemented before any ball strike risk is introduced as a result of the proposed development.
d) To enable an identified need within the Council’s Playing Pitch Strategy and Playing Pitch Mitigation Strategy to be met at the site, in accordance with NPPF paragraph 96, provisions within the policy for a 3G pitch should be made within the replacement site.
4.IV The provision for a full sized 3G pitch with sports lighting to be provided at the site.

Policy KN2 entails the relocation of the Arden Academy site. The Academy’s playing field site contains hard court provision, AGP and a number of playing pitches. The Council’s Playing Pitch Strategy identifies that there are current and future shortfalls in playing field provision. The Playing Pitch Strategy identifies that the site is used by the community, which should be formal secured via a community use agreement, and that sports provision should be replaced. In relation to the AGP the Playing Pitch Strategy states that it should replaced by a 3G pitch instead. Given the above the playing field site is not deemed to be surplus to requirement and the policy should ensure the playing field site should not be lost until a replacement provision of equivalent quantity and quality being developed and available for use.
Policy KN2 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches being utilised more intensively thus reducing their quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as the policy fails to help address shortfalls in provision as identified within an up to date evidence base document.
a) To ensure the policy is consistent with NPPF paragraph 97b, as the playing field site incorporating hard court and AGP has not been demonstrated to be surplus to requirement by the Playing Pitch Strategy and utilised by the community, the following modification is proposed to policy KN2:
2. x Development of the Arden Academy Trust playing field site (inclusive of hard court and AGP) and its ancillary facilities shall not commence until the provision of replacement playing field is made available for use. The replacement provision will be at least equivalent or better in terms quantity and quality of that proposed to be lost.
b) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy ME1 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO2 fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Policy SO1 identifies that the existing sports pitches are to be retained. Sport England consider that wording sports pitches should be replaced with ‘playing field site’ which is aligned to the wording of NPPF paragraph 97. Further to this the sports pitch layout within a playing field can alter and is not fixed on the site.
Sport England considers this modification is necessary as it would appear that the illustrative concept masterplan for the site has a road which encroaches on to the playing field site reducing the capability of site to accommodate pitches (reducing the size of pitches). No information has been submitted to justify the loss of playing field land in accordance with NPPF paragraph 97/Sport England’s Exception Policies.
Policy SO1 also fails to set out how the playing pitch demand generated from the site will be met with no reference to the Playing Pitch Strategy/Playing Pitch Mitigation Strategy. The Playing Pitch Strategy identifies shortfalls in playing field provision which will increase when taking account of future growth.
Should the site make no on-site playing field provision nor an off-site contribution, the shortfalls identified within the Playing Pitch Strategy will be exacerbated with existing pitches be utilised more intensively thus reducing its quality. For this reason, it is considered that policy is not consistent with NPPF paragraph 96 as it fails to help address shortfalls in provision as identified within an up to date evidence base document.
A) To ensure the policy wording in relation to the retention of existing playing field site in accordance with NPPF paragraph 97 the following modification is proposed:
V. iii. Retention of existing sports pitch playing field site.
B) For clarity the Concept Illustrative Masterplan should clearly set out there is no encroachment on to the playing field site.
C) To ensure the policy is consistent with NPPF paragraph 96 provision should be made within the policy to address the current and future shortfalls identified within the Playing Pitch Strategy.
The following modification is therefore proposed in relation to likely infrastructure requirements to be included within the policy:
3.V. Financial contribution to provision of new playing pitches (and ancillary facilities) and contributions to enhancement of existing recreational facilities, to accord with the requirements identified in the Playing Pitch Mitigation Strategy.

Sport England welcomes the identification of the provision of leisure and community infrastructure though the needs for the site should be informed by a Playing Pitch Strategy and Indoor Needs Assessment. To ensure that the leisure provision and playing pitch demand generated for the site is met the policy/supporting text should make reference to the need to undertake a site specific leisure and playing pitch needs assessment to inform the requirements for the site.

Sport England are supportive of policy UK2 with it ensuring the retention of the existing sports provision site until a suitable alternative site, agreed with Sport England and national governing bodies, being provided and ready for use.