From:                                         Laura Hutson <Laura.Hutson@sportengland.org>

Sent:                                           17 July 2017 15:30

To:                                               Jeremy Patterson

Subject:                                     App Ref: HS/3365/CC -  Sandown Primary School - Sport England Ref: SE/ESC/2017/46005/S

 

Dear Jeremy

 

Thank you for consulting Sport England on the above application.

 

Sport England – Statutory Role and Policy

 

It is understood that the proposal prejudices the use, or leads to the loss of use, of land being used as a playing field or has been used as a playing field in the last five years,  as defined in The Town and Country Planning (Development Management Procedure) (England) Order 2015 (Statutory Instrument 2015 No. 595). The consultation with Sport England is therefore a statutory requirement.

 

Sport England has considered the application in light of the National Planning Policy Framework (particularly Para 74) and Sport England’s Playing Fields Policy, which is presented within its Planning Policy Statement titled ‘A Sporting Future for the Playing Fields of England’ (see link below):

www.sportengland.org/playingfieldspolicy

 

Sport England’s policy is to oppose the granting of planning permission for any development which would lead to the loss of, or prejudice the use of, all/part of a playing field, unless one or more of the five exceptions stated in its policy apply.

 

The Proposal and Impact on Playing Field

It is proposed to tarmac a section of playing field (approx. 870m2) to the north of the existing school, close to an existing playground, in order to create further hard playspace. This would lead to a loss of playing field.

 

Assessment against Sport England Policy/NPPF

 

In order to satisfy E3, and claim that the ground is incapable of forming a pitch due to its poor quality/drainage, this would need to be supported by an agronomists’ report. While the applicant has provided a topographical spot height map, and mentions in the planning statement that the ground becomes boggy in winter, this alone is not considered sufficient evidence that this part of the playing field is incapable of forming a playing pitch. The spot height map provided suggests that ground levels in the entire proposal area vary by less than a metre; this level change over this area is not considered to make the field incapable of forming a playing pitch.

 

Neither does this proposal satisfy E1; Rother and Hastings councils recently undertook an extensive joint playing pitch strategy fully assessing all of the provision in the area with Sport England’s support, and this site was not highlighted as being surplus to requirements.

 

E2 is generally aimed at ancillary facilities such as changing rooms and football stands, which this clearly does not fall into. A hard play area is not considered to be ancillary to a playing field.

 

E4 is not appropriate as no replacement playing field is being proposed.

 

It is not suggested that the play area is going to be marked out for formal sport as a true multi-use games area (MUGA) might be, be floodlit, and have a good-quality surface suitable for sport (were this the case, there might be the possibility of pursuing exception E5, particularly if a community use agreement were secured).

 

Conclusion

 

In light of the above, Sport England objects to the application because it is not considered to accord with any of the exceptions to Sport England’s Playing Fields Policy or with Paragraph 74 of the NPPF.

 

Sport England would be happy to reconsider its position should further evidence be submitted as to why this part of the playing field is not considered capable of forming part of a playing pitch.

 

Should the local planning authority be minded to grant planning permission for the proposal, contrary to Sport England’s objection then in accordance with The Town and Country Planning (Consultation) (England) Direction 2009, the application should be referred to the Secretary of State, via the National Planning Casework Unit.

 

If this application is to be presented to a Planning Committee, we would like to be notified in advance of the publication of any committee agendas, report(s) and committee date(s). We would be grateful if you would advise us of the outcome of the application by sending us a copy of the decision notice. 

 

If you would like any further information or advice please contact me at the address below.

 

Yours sincerely,

 

 

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