Regulation 18 draft Local Plan

Object

Representation ID: 7124

Received: 08/01/2024

Respondent: Sport England

Kendrew Barracks at Cottesmore, St George’s Barracks at North Luffenham and HMP Stocken all contain sports facilities which should be protected from being built on as laid out in paragraph 103 of the NPPF (2023). Community use of the sports facilities at Kendrew Barracks are included in the emerging Rutland Playing Pitch Strategy along with the need for their protection. There is a need to protect these existing sports facilities. Appropriate wording should form part of one of the criteria contained in this policy.

Comments noted. The protection of sports facilities is set out in para 103 of the NPPF and Local Plan Policy SC6. These would be used in the assessment of any application affecting sports facilities at the military sites.

Object

Representation ID: 7442

Received: 08/01/2024

Respondent: Sport England

Kendrew Barracks at Cottesmore, St George’s Barracks at North Luffenham and HMP Stocken all contain sports facilities which should be protected from being built on as laid out in paragraph 103 of the NPPF (2023). Community use of the sports facilities at Kendrew Barracks are included in the emerging Rutland Playing Pitch Strategy along with the need for their protection. There is a need to protect these existing sports facilities. Appropriate wording should form part of one of the criteria contained in this policy.

Comments noted. The protection of sports facilities is set out in para 103 of the NPPF and Local Plan Policy SC6. These would be used in the assessment of any application affecting sports facilities at the military sites. Furthermore, if a masterplan or DPD is prepared, then this would include details of, and take into account, the sports facilities on the site in accordance with national planning guidance and Local Plan Policy SC6.

Object

Representation ID: 7449

Received: 08/01/2024

Respondent: Sport England

This site contains sports facilities which would either need to be retained or replaced as part of any redevelopment proposal. The retention of the sports facility may impact on the number of dwellings that could be constructed at the site.

All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.

Object

Representation ID: 7450

Received: 08/01/2024

Respondent: Sport England

This site adjoins Westray Park which is used by the community for football. There is a floodlit adult football pitch adjacent to the proposed site which is used by the community during evenings and weekends.

Paragraph 193 of the NPPF requires that new development should be integrated effectively with existing businesses and community facilities such as sports clubs. It further goes on to state that existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Therefore, the applicant (or “agent of change”) should include details of measures to protect the operation of the adjoining football pitches from any significant adverse effect arising from the siting of this new development. These mitigation measures may impact on the number of dwellings that could be constructed at the proposed housing site.

All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.

Object

Representation ID: 7451

Received: 08/01/2024

Respondent: Sport England

Objection to the wording proposed for the following reasons:

1. Fails to adequately protect the loss of sports and recreational buildings
Policy SC6 includes leisure facilities as a community facility and sets out circumstances where the loss of existing facilities might be considered acceptable. There is clear advice offered by paragraph 103 of the NPPF (2023) on how sports and recreational buildings should be protected from development.

Sport England is concerned the wording in proposed Policy is not compliant with the wording in paragraph 103. The criteria used in Policy SC6 also includes an assessment on financially viable which is not a policy requirement as laid out in paragraph 103 so should be removed for this type of development.

2. Fails to include text on the need for new community facilities as part of larger development proposals
The occupiers of new residential development would generate demand for sporting provision. The existing provision within an area may not be able to accommodate this increased demand. New development should contribute towards meeting the demand that it generates through the provision of on-site facilities and/or providing additional capacity off-site. The level and nature of any provision should be informed by a robust evidence base such as an up-to-date Sports Facilities Strategy or other relevant needs assessment.

Sport England does welcome the inclusion of its Active Design Document in the supporting text.
There is a need to update this text to refer to Sport England’s most up-to-date version of this document – “Active Design – Creating Active Environments through Planning and Design” (May 2023).

1) The loss of existing open space is covered by Policy EN7.
2) Policy SC7 sets out that development of 300+ homes would be expected to provide onsite outdoor sports facilities. If new indoor recreational facilities were to be required these would be considered strategic for the County and would be delivered through the County Council rather than by a specific development. As RCC is a Community Infrastructure Levy charging authority developer contributions towards such provision will be covered through CIL.

Reference updated as requested

Object

Representation ID: 7453

Received: 08/01/2024

Respondent: Sport England

Objection to the wording proposed for the following reasons:

1. Does not protect existing open space including playing fields
The section for Policy SC7 is entitled “Protecting Open Space for healthy and sustainable communities.” However, the policy is only written to create new open spaces and fails to include the need to protect existing open space including playing fields from being built on.

The headline findings in the emerging Playing Pitch Strategy for Rutland (Stage D) (PPS) are that there are shortfalls in the area for football and cricket pitch provision and future predicted shortfalls for football, rugby and cricket pitches. The draft recommendations of the PPS are to protect the existing quantity of playing pitches in the area.

There is a need for Policy SC7 to include a section on the clear advice offered by paragraph 103 of the NPPF (2023) on how all playing fields should be protected from development.

Sport England is concerned that Policy SC7 is not compliant with the wording in paragraph 103 and so objects to the wording of these policies which do not protect playing fields from being built on.

2. Use of a quantity standard for calculating the new provision of outdoor sports facilities.
RCC is currently working on updating its Playing Pitch Strategy (PPS) as part of its evidence base for the Local Plan Review. As mentioned in the text in Appendix 3 the adoption of an up-to-date Playing Pitch Strategy would allow the use of the Sport England playing pitch calculator.

This text on the use of Sport England’s Playing Pitch Calculator should be included in the policy wording for both on-site provision and off-site provision and the justification wording for the policy.

The text on the completion of the PPS by autumn 2023 will need to be updated to reflect the current timetable.

It is not necessary for the Local Plan to repeat national policy. Paragraph 103 of the NPPF provides clear policy for proposals which would result in the loss of open space and sports pitches. The loss of existing open space is covered by Policy EN7. An amendment is required to the title of this policy to reflect its purpose.
The new Playing Pitch Strategy 2024 has now been completed and will be used to inform changes to the policy and text.

Object

Representation ID: 7454

Received: 08/01/2024

Respondent: Sport England

The second part of this policy relates to Important Open Space which are protected by their type and are not shown in the Policies Map. The list of these “other open space” types appears to have been drafted so it is not an exhaustive list as semi-colons are used. If this list is intended to be a closed list, then it should include all playing fields and not just school playing fields.

The policy further goes on to state that important open spaces are to be safeguarded from development and any proposal for their loss will be considered against the criteria in national policy. Playing Fields are protected by their type under Paragraph 103 of the NPPF. Paragraph 103 protects all playing fields from being built and not just those in educational use. This needs to be reflected in the wording.

Comments and wording suggestions noted.