Core Strategy Submission Document
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Core Strategy Submission Document
Policy CLT5 - Open Space
Representation ID: 15774
Received: 06/10/2009
Respondent: Sport England (East Region)
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Not sound because no up-to-date evidence base on open space needs - does not meet justified or accoring with national policy criteria for following reasons:
- evidence base does not include an audit/assessment of open space, sport and recreation needs as required by PPG17 (paragrapsh 1-5)
- existing playing pitch assessment (2002) is out-of-date and would not be able to fully consider existing/future outdoor sports needs
- without needs assessment to support this policy it will be difficult to strategically plan for new open space in the core strategy, justifying protection of existing open or require new development to make provision
Not sound because no up-to-date evidence base on open space needs - does not meet justified or accoring with national policy criteria for following reasons:
- evidence base does not include an audit/assessment of open space, sport and recreation needs as required by PPG17 (paragrapsh 1-5)
- existing playing pitch assessment (2002) is out-of-date and would not be able to fully consider existing/future outdoor sports needs
- without needs assessment to support this policy it will be difficult to strategically plan for new open space in the core strategy, justifying protection of existing open or require new development to make provision
Object
Core Strategy Submission Document
Policy CLT5 - Open Space
Representation ID: 15776
Received: 06/10/2009
Respondent: Sport England (East Region)
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Would not be sound in terms of meeting the effective and national policy accordance criteria for following reasons:
- no criteria for assessing proposals affecting open space as certain types of development on open space may be acceptable e.g. ancillary facilities, sports facilities - PPG17 paragraphs 10-18 provide guidance but this is not relflected in policy
- ambiguous as the word 'usually' open to misinterpretation - criteria should be used to set out exceptions where open space will not be protected and no guidance for assessing proposals for new open space as reference only made to open space being promoted
Would not be sound in terms of meeting the effective and national policy accordance criteria for following reasons:
- no criteria for assessing proposals affecting open space as certain types of development on open space may be acceptable e.g. ancillary facilities, sports facilities - PPG17 paragraphs 10-18 provide guidance but this is not relflected in policy
- ambiguous as the word 'usually' open to misinterpretation - criteria should be used to set out exceptions where open space will not be protected and no guidance for assessing proposals for new open space as reference only made to open space being promoted
Object
Core Strategy Submission Document
Policy CLT9 - Leisure Facilities
Representation ID: 15777
Received: 06/10/2009
Respondent: Sport England (East Region)
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Policy is not considered to meet justified or national policy consistency criteria for following reasons:
Lack of robust evidence base to underpin policy. The Rochford Retail and Leisure Study is not considered to accord with guidance in PPG17 with respect to leisure/sports facilities as lack of detailed quantitative audits/assessments of all facilities in district as advocated in PPG17 guidance and assessment dependent on general household survey results rather than local consultation and use of strategic sports/leisure planning tools. Without such evidence base, difficult to justify protection of existing facilities, provision of new facilities and developer contributions.
Policy is not considered to meet justified or national policy consistency criteria for following reasons:
Lack of robust evidence base to underpin policy. The Rochford Retail and Leisure Study is not considered to accord with guidance in PPG17 with respect to leisure/sports facilities as lack of detailed quantitative audits/assessments of all facilities in district as advocated in PPG17 guidance and assessment dependent on general household survey results rather than local consultation and use of strategic sports/leisure planning tools. Without such evidence base, difficult to justify protection of existing facilities, provision of new facilities and developer contributions.
Object
Core Strategy Submission Document
Policy CLT9 - Leisure Facilities
Representation ID: 15778
Received: 06/10/2009
Respondent: Sport England (East Region)
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
While the content of this policy is partially supported, there is a concern that no guidance is provided on the criteria for assessing proposals involving new leisure facilities or development affecting existing facilities. Therefore not considered to accord with the soundness criteria relating to effectiveness as difficult to use in development control. Also guidance in PPG17 sets out the considerations for assessing new leisure facilities and proposals affecting existing facilities.
While the content of this policy is partially supported, there is a concern that no guidance is provided on the criteria for assessing proposals involving new leisure facilities or development affecting existing facilities. Therefore not considered to accord with the soundness criteria relating to effectiveness as difficult to use in development control. Also guidance in PPG17 sets out the considerations for assessing new leisure facilities and proposals affecting existing facilities.
Object
Core Strategy Submission Document
Policy CLT10 - Playing Pitches
Representation ID: 15779
Received: 06/10/2009
Respondent: Sport England (East Region)
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Does not accord with soundness criteria relating to accordance with national policy as criteria for playing pitch provision in Green Belt does not accord with PPG2. Paragraph 1.6 of PPG2 advises that providing opportunities for outdoor sport is one of the objectives of use of land in the Green Belt. Consequently, no requirement to demonstrate a need for additional playing pitches as it is not inappropriate development in Green Belt.
Does not accord with soundness criteria relating to accordance with national policy as criteria for playing pitch provision in Green Belt does not accord with PPG2. Paragraph 1.6 of PPG2 advises that providing opportunities for outdoor sport is one of the objectives of use of land in the Green Belt. Consequently, no requirement to demonstrate a need for additional playing pitches as it is not inappropriate development in Green Belt.
Object
Core Strategy Submission Document
Policy CLT10 - Playing Pitches
Representation ID: 15780
Received: 06/10/2009
Respondent: Sport England (East Region)
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Does not meet effective or accordance with national policy soundness criteria . This is because reference is made to it being acceptable for playing fields to be developed if it can be demonstrated that the site is not viable for use as playing pitch. However this is ambiguous as unclear what is meant by viable for use and does not accord with PPG17 (para 15) on development affecting playing fields which does not include any criteria relating to viability. This has potential to misinterpreted by developers e.g. any former playing field could be claimed to be unviable.
Does not meet effective or accordance with national policy soundness criteria . This is because reference is made to it being acceptable for playing fields to be developed if it can be demonstrated that the site is not viable for use as playing pitch. However this is ambiguous as unclear what is meant by viable for use and does not accord with PPG17 (para 15) on development affecting playing fields which does not include any criteria relating to viability. This has potential to misinterpreted by developers e.g. any former playing field could be claimed to be unviable.
Object
Core Strategy Submission Document
Appendix CLT1
Representation ID: 15781
Received: 06/10/2009
Respondent: Sport England (East Region)
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Not sound in terms of national policy consistency as standard charges for open space and leisure facilities only sought from residential developments. However, employment, tourism etc development also generates open space/leisure needs and PPG17 requires the needs of those working in and visiting areas to be included in assessments and planning permissions do not only apply to housing. This could result in new non-residential developments not making any provision for additional needs that they generate. Also standard charges towards open space should be expected from residential developments as not appropriate to always provide on-site e.g. playing pitches.
Not sound in terms of national policy consistency as standard charges for open space and leisure facilities only sought from residential developments. However, employment, tourism etc development also generates open space/leisure needs and PPG17 requires the needs of those working in and visiting areas to be included in assessments and planning permissions do not only apply to housing. This could result in new non-residential developments not making any provision for additional needs that they generate. Also standard charges towards open space should be expected from residential developments as not appropriate to always provide on-site e.g. playing pitches.
