Allocations Submission Document

The first objection relates to the need for more detail being required in the concept statement (paragraph 3.37) about the proposals for replacement playing field provision within the site. The proposal would result in the existing Rayleigh Town Sports & Social Club site which has a range of pitches and clubhouse facilities used by local football, cricket and other sports club needing to be replaced within the development. While it is acknowledged that it is the Council's intention that the playing field and ancillary facilities would be replaced before the removal of the existing facilities, the policy has the following shortcomings:
1. It has not been made explicit in the concept statement that the replacement playing field and ancillary facilities will need to be equivalent or better in both quantity and quality to the facilities that would be lost. Without this, there is a concern that the replacement pitches, clubhouse, parking etc could be inferior in size, design, quality etc to the facilities that they would replace. Policy CLT10 of the Council's adopted core strategy resists the loss of playing pitches unless their replacement is equal or better and paragraph 74 of the NPPF as well as Sport England's playing fields policy also takes this policy approach. Clarity on this point is therefore required for consistency with national policy and the Council's core strategy. It is also advocated that the replacement playing pitches and ancillary facilities will be required to meet the design guidance of Sport England and the relevant sports governing bodies in order to ensure that the facilities are of a suitable quality and fit for purpose from a sports perspective as well as an environmental perspective (BREEAM).
2. It has not been made explicit in the concept statement that the replacement playing field and ancillary facilities will need to be subject to at least equivalent management arrangements to the existing facilities. The current Rayleigh Sports & Social Club site will presumably be either owned on a freehold basis by the club or the subject of a long term lease. This is necessary to provide security of tenure and to help facilitate investment in maintaining and improving the facilities for the community. No mention is made of this in the policy and consequrently there is a concern that the replacement facilities could be subject to inferior tenure/management arrangements e.g. short leases, hire arrangements etc which would be unacceptable and could prejudice the long term viability of the club facilities. Sport England's playing fields policy requires replacement playing fields to be at least equivalent in terms of management arrangements to avoid such scenarios. Clarity on this point is therefore required for consistency with national policy.
3. The proposal to relocate the club within the development site would be acceptable in terms of the broad location as this should not affect existing users of the facilities. However, to avoid a scenario where a planning application is submitted which proposes an unsuitable location and access for the sports club it is advocated that that the policy makes provision for a master plan/framework plan for the whole site to be submitted and approved in advance of any planning application in order to ensure that the location is acceptable in practice. This would also be helpful for addressing the other planning requirements set out in the concept statement in view of the size and complexity of the proposed allocation. Without this there is a risk that a planning application will be progressed which does not make provision for for a suitable replacement facility in terms of location/access.
4. The proposal for the clubhouse and associated development to be positioned adjacent to the new residential settlement is of potential concern because the use of the current Rayleigh Sports & Social Club's clubhouse for social functions during the evenings/weekends would riase potential residential amenity concerns such as noise. At present, this would not appear to be an issue as the clubhouse is not located in close proximity to residential development. However, if a new clubhouse had to be integrated with adjoining residential development this would threaten the continuity of using the clubhouse for such events (e.g. the licence could be removed). As sports clubs rely heavily on the revenue raised from social functions and bar use for maintaining and improving the sports facility it is considered essential that the relocated facilities do not prejudice the replacement clubhouse from being used for such purposes as this could affect the long term viability of the facilities. Consequently, the reference in the concept statement should be amended to make provision for the clubhouse and associated facilities being relocated where the continued use of the clubhouse for social functions will not be prejudiced by residential amenity concerns.
5. As Sport England will be a statutory consultee on any future planning application due to the loss of playing fields, it is requested that the concept statement makes reference to the need for engagement with Sport England before a planning application is submitted in order to ensure that the issues raised above can be satisfactorily addressed in practice in order to avoid the potential delays and uncertainty associated with delivering the residential development if a statutory objection is made due to replacement playing field provision not being considered acceptable.

The second objection relates to the lack of provision within the policy for providing additional outdoor sports facilities to meet the additional needs generated by the development. The Council's Playing Pitch Strategy has assessed playing pitch needs and has identified deficiencies across the district especially for mini and junior football pitches. Such deficiencies would be aggrevated by the additional population associated with the new development unless provision was made for meeting these additional needs. It should be noted that paragraph 6.12 of the Playing Pitch Strategy specfically refers to when opportunities arising for providing new pitches they should be on the western side of the district in Rayleigh. Policy CLT5 of the adopted core strategy refers to the need for residential development to provide new open space and specifically refers to residential development in the west of Rayleigh incorporating a significant amount of open space. While the concept statement makes provision for youth facilities and play space to be provided within the development it is therefore surprising in the context of the core strategy policies and the evidence base provided by the playing pitch strategy that no specific provision is made for the development providing additional playing pitch provision. The proposed allocation provides a rare opportunity for new playing pitch provision to be provided in an area where an identified need exists. As it is proposes that a replacement playing field is to bprovided for Rayleigh Town Sports & Social Club, an obvious and appropriate way to address this would be for the policy to make provision for the replacement playing field and ancillary facilities to be extended to incorporate additional facility provision to meet the needs of the development. This would allow the football, cricket etc clubs that use the facilities to expand to incorporate the additional needs genertaed by the development. In its current form the policy is not considered to meet the soundness tests relating to being justified and consistent with national policy as the proposals do not respond to needs justified by the Council's evidence base and core strategy policies or accord with NPPF policy e.g. paragraph 73 which advises assessments of need for sports facilities to be used for determining what sports provision is required.

Objection is made to the lack of provision within the policy for providing additional outdoor sports facilities to meet the additional needs generated by the development. The Council's Playing Pitch Strategy has assessed playing pitch needs and has identified deficiencies across the district especially for mini and junior football pitches. Such deficiencies would be aggrevated by the additional population associated with the new development unless provision was made for meeting these additional needs. While the concept statement makes provision for youth facilities, play space and lesiure facilities to be provided no explicit proviison is amde for playing pitches which is it is surprising in the context of the core strategy policies and the evidence base provided by the playing pitch strategy. The proposed allocation provides a rare opportunity for new playing pitch provision to be provided. In its current form the policy is not considered to meet the soundness tests relating to being justified and consistent with national policy as the proposals do not respond to needs justified by the Council's evidence base and core strategy policies or accord with NPPF policy e.g. paragraph 73 which advises assessments of need for sports facilities to be used for determining what sports provision is required.

Objection is made to the lack of provision within the policy for providing additional outdoor sports facilities to meet the additional needs generated by the development. The Council's Playing Pitch Strategy has assessed playing pitch needs and has identified deficiencies across the district especially for mini and junior football pitches. Such deficiencies would be aggrevated by the additional population associated with the new development unless provision was made for meeting these additional needs. While the concept statement makes provision for youth facilities, play space and community facilities to be provided no explicit provision is made for playing pitches which is surprising in the context of the core strategy policies and the evidence base provided by the playing pitch strategy. The proposed allocation provides a rare opportunity for new playing pitch provision to be provided. In its current form the policy is not considered to meet the soundness tests relating to being justified and consistent with national policy as the proposals do not respond to needs justified by the Council's evidence base and core strategy policies or accord with NPPF policy e.g. paragraph 73 which advises assessments of need for sports facilities to be used for determining what sports provision is required.