Local Plan Review: Preferred Approach 2016-2035

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

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

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

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

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

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

Protecting playing fields and sport facilities
Currently the NPPF states:
Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:
* an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements
* the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location
* the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.
Policy DM34: Open Space, Sport and Recreation including Indoor Sports Facilities and Playing Pitches

The Council will seek to retain, enhance, improve access and increase the quantity and quality of public open space, playing fields, sport and recreation facilities (including indoor facilities) and rights of way including improvement of links to them.

Development involving their loss will be granted permission where all the following criteria have been addressed:

1. Alternative accessible replacement facilities of overall at least equivalent quantity and quality are provided: or
2. Where the Chichester Open Space, Sport and Recreation Study (including Indoor Sports Facilities) and Playing Pitch Strategy identifies a surplus of provision, future needs and the potential of the open space to meet any shortfall in other types of provision in the local area have been taken into account; and
3. There are no adverse impacts on biodiversity, heritage assets or the integrity of the Green Infrastructure network.

Exceptions will only be made where the benefit of the development outweighs any harm, and it can be demonstrated there are no reasonable alternative sites available.

Currently it is Sport England's position that this policy requires rewording in order to be in line with the NPPF. First, it suggests that all criteria must be met, then states that either 1 or 2 must be met - this contradicts each other. The sentence regarding exceptions should also be reworded to ensure that it is clear that any new development considered to outweigh the loss should be for alternative sports and recreational provision rather than for any other type of development, in order to be in line with national policy.

Please note that without the proposed rewording Sport England will object to this policy.

Economic development
It is noted that the economy is a key issue within the Chichester Local Plan.

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


Policy S21: Health and Wellbeing
I note that this policy states:

All proposals for new development should improve and promote strong, vibrant and healthy communities. Measures that contribute to healthier communities and support health, social and cultural wellbeing, must be incorporated in a development where appropriate.

Sport England broadly supports this and is of the view that this policy could be strengthened through reference to Sport England's Active Design guidance. We believe that being active should be an intrinsic part of everyone's daily life - and the design of where we live and work plays a vital role in keeping us active. Good design should contribute positively to making places better for people and create environments that make the active choice the easy choice for people and communities. That's why Sport England, in partnership with Public Health England, has produced the Active Design Guidance. This guidance builds on the original Active Design (2007) objectives of improving accessibility, enhancing amenity and increasing awareness, and sets out the Ten Principles of Active Design.

Ten principles
The ten principles have been developed to inspire and inform the layout of cities, towns, villages, neighbourhoods, buildings, streets and open spaces, to promote sport and active lifestyles.
The guide features an innovative set of guidelines to get more people moving through suitable design and layout. It includes a series of case studies setting out practical real-life examples of the principles in action to encourage planners, urban designers, developers and health professionals to create the right environment to help people get more active, more often.
The Active Design Principles are aimed at contributing towards the Government's desire for the planning system to promote healthy communities through good urban design.
Active Design has been produced in partnership with David Lock Associates, specialists in town planning and urban design.

http://sportengland.org/facilities-planning/planning-for-sport/planning-tools-and-guidance/active-design

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

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

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

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

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

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

Protecting playing fields and sport facilities
Currently the NPPF states:
Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:
* an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements
* the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location
* the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.
Policy DM34: Open Space, Sport and Recreation including Indoor Sports Facilities and Playing Pitches

The Council will seek to retain, enhance, improve access and increase the quantity and quality of public open space, playing fields, sport and recreation facilities (including indoor facilities) and rights of way including improvement of links to them.

Development involving their loss will be granted permission where all the following criteria have been addressed:

1. Alternative accessible replacement facilities of overall at least equivalent quantity and quality are provided: or
2. Where the Chichester Open Space, Sport and Recreation Study (including Indoor Sports Facilities) and Playing Pitch Strategy identifies a surplus of provision, future needs and the potential of the open space to meet any shortfall in other types of provision in the local area have been taken into account; and
3. There are no adverse impacts on biodiversity, heritage assets or the integrity of the Green Infrastructure network.

Exceptions will only be made where the benefit of the development outweighs any harm, and it can be demonstrated there are no reasonable alternative sites available.

Currently it is Sport England's position that this policy requires rewording in order to be in line with the NPPF. First, it suggests that all criteria must be met, then states that either 1 or 2 must be met - this contradicts each other. The sentence regarding exceptions should also be reworded to ensure that it is clear that any new development considered to outweigh the loss should be for alternative sports and recreational provision rather than for any other type of development, in order to be in line with national policy.

Please note that without the proposed rewording Sport England will object to this policy.

Economic development
It is noted that the economy is a key issue within the Chichester Local Plan.

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


Policy S21: Health and Wellbeing
I note that this policy states:

All proposals for new development should improve and promote strong, vibrant and healthy communities. Measures that contribute to healthier communities and support health, social and cultural wellbeing, must be incorporated in a development where appropriate.

Sport England broadly supports this and is of the view that this policy could be strengthened through reference to Sport England's Active Design guidance. We believe that being active should be an intrinsic part of everyone's daily life - and the design of where we live and work plays a vital role in keeping us active. Good design should contribute positively to making places better for people and create environments that make the active choice the easy choice for people and communities. That's why Sport England, in partnership with Public Health England, has produced the Active Design Guidance. This guidance builds on the original Active Design (2007) objectives of improving accessibility, enhancing amenity and increasing awareness, and sets out the Ten Principles of Active Design.

Ten principles
The ten principles have been developed to inspire and inform the layout of cities, towns, villages, neighbourhoods, buildings, streets and open spaces, to promote sport and active lifestyles.
The guide features an innovative set of guidelines to get more people moving through suitable design and layout. It includes a series of case studies setting out practical real-life examples of the principles in action to encourage planners, urban designers, developers and health professionals to create the right environment to help people get more active, more often.
The Active Design Principles are aimed at contributing towards the Government's desire for the planning system to promote healthy communities through good urban design.
Active Design has been produced in partnership with David Lock Associates, specialists in town planning and urban design.

http://sportengland.org/facilities-planning/planning-for-sport/planning-tools-and-guidance/active-design

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

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

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

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

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

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

Protecting playing fields and sport facilities
Currently the NPPF states:
Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:
* an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements
* the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location
* the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.
Policy DM34: Open Space, Sport and Recreation including Indoor Sports Facilities and Playing Pitches

The Council will seek to retain, enhance, improve access and increase the quantity and quality of public open space, playing fields, sport and recreation facilities (including indoor facilities) and rights of way including improvement of links to them.

Development involving their loss will be granted permission where all the following criteria have been addressed:

1. Alternative accessible replacement facilities of overall at least equivalent quantity and quality are provided: or
2. Where the Chichester Open Space, Sport and Recreation Study (including Indoor Sports Facilities) and Playing Pitch Strategy identifies a surplus of provision, future needs and the potential of the open space to meet any shortfall in other types of provision in the local area have been taken into account; and
3. There are no adverse impacts on biodiversity, heritage assets or the integrity of the Green Infrastructure network.

Exceptions will only be made where the benefit of the development outweighs any harm, and it can be demonstrated there are no reasonable alternative sites available.

Currently it is Sport England's position that this policy requires rewording in order to be in line with the NPPF. First, it suggests that all criteria must be met, then states that either 1 or 2 must be met - this contradicts each other. The sentence regarding exceptions should also be reworded to ensure that it is clear that any new development considered to outweigh the loss should be for alternative sports and recreational provision rather than for any other type of development, in order to be in line with national policy.

Please note that without the proposed rewording Sport England will object to this policy.

Economic development
It is noted that the economy is a key issue within the Chichester Local Plan.

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


Policy S21: Health and Wellbeing
I note that this policy states:

All proposals for new development should improve and promote strong, vibrant and healthy communities. Measures that contribute to healthier communities and support health, social and cultural wellbeing, must be incorporated in a development where appropriate.

Sport England broadly supports this and is of the view that this policy could be strengthened through reference to Sport England's Active Design guidance. We believe that being active should be an intrinsic part of everyone's daily life - and the design of where we live and work plays a vital role in keeping us active. Good design should contribute positively to making places better for people and create environments that make the active choice the easy choice for people and communities. That's why Sport England, in partnership with Public Health England, has produced the Active Design Guidance. This guidance builds on the original Active Design (2007) objectives of improving accessibility, enhancing amenity and increasing awareness, and sets out the Ten Principles of Active Design.

Ten principles
The ten principles have been developed to inspire and inform the layout of cities, towns, villages, neighbourhoods, buildings, streets and open spaces, to promote sport and active lifestyles.
The guide features an innovative set of guidelines to get more people moving through suitable design and layout. It includes a series of case studies setting out practical real-life examples of the principles in action to encourage planners, urban designers, developers and health professionals to create the right environment to help people get more active, more often.
The Active Design Principles are aimed at contributing towards the Government's desire for the planning system to promote healthy communities through good urban design.
Active Design has been produced in partnership with David Lock Associates, specialists in town planning and urban design.

http://sportengland.org/facilities-planning/planning-for-sport/planning-tools-and-guidance/active-design

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

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

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

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

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

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

Protecting playing fields and sport facilities
Currently the NPPF states:
Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:
* an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements
* the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location
* the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.
Policy DM34: Open Space, Sport and Recreation including Indoor Sports Facilities and Playing Pitches

The Council will seek to retain, enhance, improve access and increase the quantity and quality of public open space, playing fields, sport and recreation facilities (including indoor facilities) and rights of way including improvement of links to them.

Development involving their loss will be granted permission where all the following criteria have been addressed:

1. Alternative accessible replacement facilities of overall at least equivalent quantity and quality are provided: or
2. Where the Chichester Open Space, Sport and Recreation Study (including Indoor Sports Facilities) and Playing Pitch Strategy identifies a surplus of provision, future needs and the potential of the open space to meet any shortfall in other types of provision in the local area have been taken into account; and
3. There are no adverse impacts on biodiversity, heritage assets or the integrity of the Green Infrastructure network.

Exceptions will only be made where the benefit of the development outweighs any harm, and it can be demonstrated there are no reasonable alternative sites available.

Currently it is Sport England's position that this policy requires rewording in order to be in line with the NPPF. First, it suggests that all criteria must be met, then states that either 1 or 2 must be met - this contradicts each other. The sentence regarding exceptions should also be reworded to ensure that it is clear that any new development considered to outweigh the loss should be for alternative sports and recreational provision rather than for any other type of development, in order to be in line with national policy.

Please note that without the proposed rewording Sport England will object to this policy.

Economic development
It is noted that the economy is a key issue within the Chichester Local Plan.

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


Policy S21: Health and Wellbeing
I note that this policy states:

All proposals for new development should improve and promote strong, vibrant and healthy communities. Measures that contribute to healthier communities and support health, social and cultural wellbeing, must be incorporated in a development where appropriate.

Sport England broadly supports this and is of the view that this policy could be strengthened through reference to Sport England's Active Design guidance. We believe that being active should be an intrinsic part of everyone's daily life - and the design of where we live and work plays a vital role in keeping us active. Good design should contribute positively to making places better for people and create environments that make the active choice the easy choice for people and communities. That's why Sport England, in partnership with Public Health England, has produced the Active Design Guidance. This guidance builds on the original Active Design (2007) objectives of improving accessibility, enhancing amenity and increasing awareness, and sets out the Ten Principles of Active Design.

Ten principles
The ten principles have been developed to inspire and inform the layout of cities, towns, villages, neighbourhoods, buildings, streets and open spaces, to promote sport and active lifestyles.
The guide features an innovative set of guidelines to get more people moving through suitable design and layout. It includes a series of case studies setting out practical real-life examples of the principles in action to encourage planners, urban designers, developers and health professionals to create the right environment to help people get more active, more often.
The Active Design Principles are aimed at contributing towards the Government's desire for the planning system to promote healthy communities through good urban design.
Active Design has been produced in partnership with David Lock Associates, specialists in town planning and urban design.

http://sportengland.org/facilities-planning/planning-for-sport/planning-tools-and-guidance/active-design