Subject: FW: App Ref: WD/3423/CC- Hailsham Community College, Battle Road, BN27
1DT- Sport England Ref: PA/20/SE/ESC/56211
From: Jo Edwards
Sent: 25 August 2020 6:19 PM
To: Kiran Sajjan
Subject: [Sender Unverified]App Ref: WD/3423/CC- Hailsham Community
College, Battle Road, BN27 1DT- Sport England Ref: PA/20/SE/ESC/56211
Dear Kiran
Thank you for consulting Sport England
on this 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 (in particular
Para. 97), and against its own playing fields policy, which states:
'Sport England will oppose the
granting of planning permission for any development which would lead to the
loss of, or would prejudice the use of:
- all or any part of a playing
field, or
- land which has been used as a
playing field and remains undeveloped, or
- land allocated for use as a
playing field
unless, in the judgement of Sport
England, the development as a whole meets with one or more of five specific
exceptions.'
Sport England's Playing Fields Policy
and Guidance document can be viewed via the below link:
The Proposal and Impact on Playing
Field
The proposal is for development to
expand the college buildings and site to include the provision of additional
car (46 spaces) and cycle parking (20 spaces) on part of the playing field to
the south of the existing sand based All Weather Pitch, and the construction of
a new flood lit All Weather Sports Pitch (AWP) in the south east part of the
playing field. As indicated on the proposed site layout drawing 1013-S1 Rev B
the new AWP would be marked out for football use predominantly and have an
approximate pitch size of 73m x 46m within a fenced enclosure of 102m x 54m.
The rugby pitch would be moved to the
north of its current location to where one of the two football grass pitches is
currently marked out.
Assessment against Sport England
Policy
This application as it relates to the
proposed AWP is for the provision of a new indoor/outdoor sports facility on
the existing playing field at the above site. It therefore needs to be
considered against exception 5 of the above policy, which states:
'The proposed development is for an
indoor or outdoor facility for sport, the provision of which would be of
sufficient benefit to the development of sport as to outweigh the detriment
caused by the loss, or prejudice to the use, of the area of playing field.'
Sport England assesses the potential
benefit of the new or extended sports facility by taking into account a number
of considerations. As a guide, these may include whether the facility:
- meets an identified local or
strategic need e.g. as set out in a local authority or NGB strategy
(rather than duplicating existing provision);
- fully secures sport related
benefits for the local community;
- helps to meet identified sports
development priorities;
- complies with relevant Sport
England and NGB design guidance;
- improves the delivery of sport
and physical education on school sites; and
- is accessible by alternative
transport modes to the car.
Proposals will also need to
demonstrate that the loss of any area of playing field will not have an
unacceptable impact on the current and potential playing pitch provision on the
site. For example, it is unlikely that a loss would be acceptable if:
- it would result in the main
user (e.g. a school or a club) being unable to meet their own minimum
requirements for playing pitches (the Department for Education provide
area guidelines for playing fields at existing schools and academies).
- other users would be displaced
without equivalent replacement provision;
- it would materially reduce the
capability and flexibility of the playing field to provide for a range of
sports and natural grass playing pitches; or the area of playing field is
significant in meeting local or strategic needs.
The Wealden Playing Pitch and Outdoor
Needs Assessment 2016-2018 identifies that additional full sized (100m x 64m)
3G AWPs are required in the District to meet existing and future demand. The
Wealden Local Football Facilities Plan (LFFP) May 2019 prepared by the
Football Foundation with the District Council identifies that currently there is
only one full sized (11v11) 3G pitch in the District at Uckfield Leisure Centre
and a shortfall of four full sized 3Gs relative to assessed demand.
The existing full sized 3G is located
in the west of the substantial LA area meaning that there are significant gaps
of provision in each of the north, south and central areas despite there being
settlements with substantial levels of population in these areas. The LFFP
seeks to address those deficiencies, identifying two potential sites in the
Hailsham area, either one of which could be developed with a full sized 3G
pitch. The first of these is the Community College and the second, Maurice
Thornton Playing Field. The LFFP as rationale for provision here states; Rationale: a need to provide a full size
3G FTP in the Hailsham area. An area with high football demand with potential
for increased recreational demand too. Man Against Fat players from Hailsham
currently having to travel to Eastbourne and Crowborough due to lack of
appropriate facilities. Hailsham is also due to have significant housing
growth. Project focus
should be on; Adult female; Adult male; Disability; IMD / lower social
economic groups; Mini-soccer; Small-sided recreational; Small-sided teams and
leagues; Youth female; Youth male
Sport England is therefore satisfied
that there is an identified strategic need for a full sized 3G facility here.
In preparing its response to this application, I have also consulted the
Football Foundation and County FA who have expressed support for the provision
of a 3G here in principle. However it has asked that the College gives
consideration to providing a full sized pitch (100m x64m) built to FA
specification that would require further run off and spectator areas. It
recognises that that may not be possible, due to the required provision for
other sports on the playing field (and also in this instance the presence of
the oak tree to be protected) however Sport England would support the NGB’s
request that further consideration is given to the feasibility of providing a
full sized or closer to full sized 3G pitch here given the significant demand
for full sized 3G in the Hailsham area.
Irrespective of pitch size the
following aspects of the development should be secured to ensure that the
benefits of the proposed 3G AWP outweigh the loss of the existing area of
playing field and meet Sport England’s assessment criteria for achieving
exception 5:
Construction Quality –
Ensure the pitch is constructed to the FIFA Quality Concept for Football Turf –
FIFA Quality (old FIFA 1*) accreditation
Testing – That the 3G pitch is
tested and subsequently FA registered on completion and then every three years
for grassroots football.
Pricing - Pricing policies must
be affordable for grass roots football clubs and should be agreed with the
local County Football Association. This should include match-rates at weekends
equivalent to the Local Authorities price for natural turf pitches.
Sinking fund - Ensure that sinking
funds (formed by periodically setting aside money over time ready for surface
replacement when required – FA recommend £25k per annum (in today’s market for
a full size pitch) are in place to maintain 3G pitch quality in the long term
These aspects should be
secured by conditions as recommended below.
Design:
- 3G AGP designs needs to be in line with FA
recommendation but should be checked against The FA Guide to Football Turf
Pitch Design Principles and Layouts, including a spectator area.
- Line marking – the FF recommends that
over-marking are made to allow different formats of football (e.g. 5v5,
7v7, 9v9 and 11v11). Over-marking should adhere to The FA Guide to
Football Turf Pitch Design Principles and Layouts and can be painted on.
- Recessed fencing – the FF recommends that
the fencing is recessed to allow for safe and easy goal storage.
- Fence height – The FA recommend fence
height on all sides of the a 3G AGP is 4.5m.
- Run-off - A minimum 3m run off
- Floodlighting – minimum average maintained
200 lux
With regard to that part of the
playing field to be developed for additional car and cycle parking, Sport
England is satisfied that the proposal broadly meets exception 3 in that
'The proposed development affects only
land incapable of forming part of a playing pitch and does not:
- reduce the size of any playing
pitch
- result in the inability to use
any playing pitch (including the maintenance of adequate safety margins
and run-off areas);
- reduce the sporting capacity of
the playing field to accommodate playing pitches or the capability to
rotate or reposition playing pitches to maintain their quality;
- result in the loss of other
sporting provision or ancillary facilities on the site; or
- prejudice the use of any
remaining areas of playing field on the site.'
Conclusions and Recommendation
Given the above assessment, Sport
England does not wish to raise an objection to this application as it is
considered to meet/broadly meet exceptions 5 and 3 of the above policy. The
absence of an objection is subject to the following condition(s) being attached
to the decision notice should the local planning authority be minded to approve
the application:
Condition 1.
Use of the development
shall not commence until:
certification
that the Artificial Grass Pitch hereby permitted has met FIFA Quality Concept
for Football Turf – FIFA Quality or equivalent International Artificial Turf
Standard (IMS); and
confirmation
that the facility has been registered on the Football Association’s Register of
Football Turf Pitches
have been
submitted to and approved in writing by the Local Planning Authority.
Reason:
To ensure the development is fit for purpose and sustainable, provides
sporting benefits and to accord with Development Plan Policy **.
Condition 2.
Use of the development shall not commence [or no development shall
commence or such other timescale] until a community use agreement prepared in
consultation with Sport England has been submitted to and approved in writing
by the Local Planning Authority, and a copy of the completed approved agreement
has been provided to the Local Planning Authority. The agreement shall
apply to the 3G football AWP and include details of pricing policy, hours of use,
access by non-[educational establishment] users [/non-members], management
responsibilities and a mechanism for review. The development shall not be
used otherwise than in strict compliance with the approved agreement.
Reason:
To secure well managed safe community access to the sports facility/facilities,
to ensure sufficient benefit to the development of sport and to accord with
Development Plan Policy **.
Informative: Guidance on preparing Community Use
Agreements is available from Sport England.
http://www.sportengland.org/planningapplications/ For artificial grass pitches
it is recommended that you seek guidance from
the Football Association on pitch
construction when determining the community use hours the artificial pitch can
accommodate.
Condition 3.
Before the 3G football AWP is
brought into use, a Management and Maintenance Scheme for the facility
including management responsibilities, a maintenance schedule, a mechanism for
review and measures to ensure the replacement of the Artificial Grass Pitch
within a specified period shall be submitted to and approved in writing by the
Local Planning Authority after consultation with Sport England and The measures
set out in the approved scheme shall be complied with in full, with effect from
commencement of use of the AWP.
Reason: To
ensure that a new facility is capable of being managed and maintained to
deliver [a facility/facilities] which is fit for purpose, sustainable and to
ensure sufficient benefit of the development to sport and to accord
with Development Plan Policy **.
If you wish to amend the wording of
the recommended condition(s), or use another mechanism in lieu of the
condition(s), please discuss the details with the undersigned. Sport England
does not object to amendments to conditions, provided they achieve the same
outcome and we are involved in any amendments.
There is a free online resource from
Sport England (Use Our School) that offers further guidance and information for
local authorities and other education providers on how to make the best use of
school facilities for the benefit of the local community. It is especially
useful for those who have responsibility within a school for establishing,
sustaining and growing community activity on school sites. 'Use Our School' can
be accessed here; www.sportengland.org/useourschool
Sport England would also like to be
notified of the outcome of the application through the receipt of a copy of the
decision notice.
The absence of an objection to this
application, in the context of the Town and Country Planning Act, cannot be
taken as formal support or consent from Sport England or any National Governing
Body of Sport to any related funding application, or as may be required by
virtue of any pre-existing funding agreement.
If you would like any further
information or advice, please contact me at the address below.
Yours
sincerely,
Jo Edwards
Planning Manager
|
|
||||||||||
|
|
||||||||||
|
The information contained in this
e-mail may be subject to public disclosure under the Freedom of Information Act
2000. Additionally, this email and any attachment are confidential and intended
solely for the use of the individual to whom they are addressed. If you are not
the intended recipient, be advised that you have received this email and any
attachment in error, and that any use, dissemination, forwarding, printing, or
copying, is strictly prohibited. If you voluntarily provide personal data by
email, Sport England will handle the data in accordance with its Privacy
Statement. Sport England’s Privacy Statement may be found here
https://www.sportengland.org/privacy-statement/ If you have any queries about
Sport England’s handling of personal data you can contact Louise Hartley, Sport
England’s Data Protection Officer directly by emailing DPO@sportengland.org