1

Carly Herod

Subject: FW: Neighbourhood and Communities Services Committee - Oakfield's and Ford Sports Ground

  

From: Katy Walker [mailto:Katy.Walker@sportengland.org] Sent: 29 May 2015 16:43 To: John Pearce Cc: Stuart Makepeace; Charles Johnston; Simon Barry; Iain Varah Subject: Neighbourhood and Communities Services Committee - Oakfield's and Ford Sports Ground Importance: High   Dear Mr Pearce,   Sport England notes the published recommendation report in connection with the meeting of the above named Committee on 3 June. Sport England has some pressing concerns that it wanted to raise with you directly.   As you may be aware, Sport England has been in dialogue with Simon Barry, Chief Environmental Housing and Community Services Officer and Ian Varah regarding the proposals for Oakfield’s and Ford Sports Ground. When we last met there was a commitment to working together to ensure that the strategic needs for sport are safeguarded. Sport England welcomes this ongoing dialogue.   Notwithstanding that, Sport England has previously set out that should the Local Plan proceed to allocate the  Oakfield’s and Ford Sports Ground for housing, then replacement provision should be positively planned for and replacement land allocated as part of the Local Plan – it cannot be left an unknown.  In that regard, there are two areas of the 3 June Committee Report that cause some concern:   

1. Firstly, there appears to be no mention within the Committee Report to Sport England’s representations on this matter. Sport England has an established role within the planning system as a statutory consultee and it represents a sporting voice at a national and strategic level. Only in exceptional circumstances does Sport England, the FA and ECB come together to submit a joint letter of opposition of kind submitted (as attached for your ease of reference). It is felt that its significance deserves greater acknowledgement in the Committee Report and that the Committee would benefit from knowing the views of National Governing Bodies for Sport and Sport England.   

2. The second mater relates to section “10. Additional evidence base document” paragraph (g) of the Committee Report. There are some areas of factual inaccuracy, which need to be brought to your attention as they inadvertently may act to misinform the Committee. Firstly, the requirement for  a robust and 

up-to-date assessments of the needs for sports facilities is set out in paragraph 73 and not 74 as 

suggested.  It should be noted that the requirement for a robust and up-to-date assessments of the needs exists in any event and irrespective of whether  the Local Plan is proposing the loss of playing field land. If 

the Local Plan is taken to Examination without the benefit of a robust and up-to-date assessment (playing pitch strategy) there is a risk that the Local Plan could be found unsound, as has been the case for some other authorities.    In addition, the Committee report suggests that Policy 26 complies with paragraph 74 of the NPPF as the policy indicates that any playing field lost would be replaced. However, given that the Local Plan does not allocate replacement playing field land which is of equivalent in quantity and quality this has not been demonstrated. The Local Plan must positively plan for and allocate land for playing field in the same way that it seeks to allocate land for housing. The lack of an identified site or sites which are viable and demonstrably deliverable is something that is likely (in Sport England’s experience) to be challenged by Inspector at Examination. Sport England is concerned that the wording of paragraph (g) suggests a policy compliant approach, but the Committee ought to be made aware that there is a real risk of this approach being open to challenge and that there is a risk of taking the Local Plan to EiP without the Playing Pitch Strategy having been completed and/ or replacement (viable and deliverable) sites being allocated within the Local Plan. 

2

  Sport England requests that changes be made or a supplementary note prepared to the Committee Report that reflects the matters raised above. Alternative, Sport Englnad would not object to this correspondence being shared with Committee Members.   Your acknowledgement of receipt of this email and an indication of how you wish to proceed would be most welcomed.   Yours sincerely Katy Walker Principal Planning Manager T: 020 7273 1906 E: katy.walker@sportengland.org Sport England's London office has moved to 1st Floor, 21 Bloomsbury Street, London, WC1B 3HF  

 Creating a sporting habit for life 

 

  

National Sports Centre, near Marlow, Buckinghamshire, SL7 1RR   

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,

1

Carly Herod

Subject: FW: Neighbourhood and Communities Services Committee - Oakfield's and Ford Sports Ground

Attachments: 16 Dec 2014 - Sport England, ECB and FA joint objection to Core Strategy.pdf; 20141001 Oakfields Neighbourhoods and Communities Services Committee.pdf

Importance: High

 

From: Katy Walker [mailto:Katy.Walker@sportengland.org] Sent: 29 May 2015 16:43 To: John Pearce Cc: Stuart Makepeace; Charles Johnston; Simon Barry; Iain Varah Subject: Neighbourhood and Communities Services Committee - Oakfield's and Ford Sports Ground Importance: High  Dear Mr Pearce,   Sport England notes the published recommendation report in connection with the meeting of the above named Committee on 3 June. Sport England has some pressing concerns that it wanted to raise with you directly.   As you may be aware, Sport England has been in dialogue with Simon Barry, Chief Environmental Housing and Community Services Officer and Ian Varah regarding the proposals for Oakfield’s and Ford Sports Ground. When we last met there was a commitment to working together to ensure that the strategic needs for sport are safeguarded. Sport England welcomes this ongoing dialogue.   Notwithstanding that, Sport England has previously set out that should the Local Plan proceed to allocate the  Oakfield’s and Ford Sports Ground for housing, then replacement provision should be positively planned for and replacement land allocated as part of the Local Plan – it cannot be left an unknown.  In that regard, there are two areas of the 3 June Committee Report that cause some concern:   

1. Firstly, there appears to be no mention within the Committee Report to Sport England’s representations on this matter. Sport England has an established role within the planning system as a statutory consultee and it represents a sporting voice at a national and strategic level. Only in exceptional circumstances does Sport England, the FA and ECB come together to submit a joint letter of opposition of kind submitted (as attached for your ease of reference). It is felt that its significance deserves greater acknowledgement in the Committee Report and that the Committee would benefit from knowing the views of National Governing Bodies for Sport and Sport England.   

2. The second mater relates to section “10. Additional evidence base document” paragraph (g) of the Committee Report. There are some areas of factual inaccuracy, which need to be brought to your attention as they inadvertently may act to misinform the Committee. Firstly, the requirement for  a robust and 

up-to-date assessments of the needs for sports facilities is set out in paragraph 73 and not 74 as 

suggested.  It should be noted that the requirement for a robust and up-to-date assessments of the needs exists in any event and irrespective of whether  the Local Plan is proposing the loss of playing field land. If 

the Local Plan is taken to Examination without the benefit of a robust and up-to-date assessment (playing pitch strategy) there is a risk that the Local Plan could be found unsound, as has been the case for some other authorities.    In addition, the Committee report suggests that Policy 26 complies with paragraph 74 of the NPPF as the policy indicates that any playing field lost would be replaced. However, given that the Local Plan does not allocate replacement playing field land which is of equivalent in quantity and quality this has not been demonstrated. The Local Plan must positively plan for and allocate land for playing field in the same way that it seeks to allocate land for housing. The lack of an identified site or sites which are viable and demonstrably deliverable is something that is likely (in Sport England’s experience) to be challenged by Inspector at Examination. Sport England is concerned that the wording of paragraph (g) suggests a policy 

2

compliant approach, but the Committee ought to be made aware that there is a real risk of this approach being open to challenge and that there is a risk of taking the Local Plan to EiP without the Playing Pitch Strategy having been completed and/ or replacement (viable and deliverable) sites being allocated within the Local Plan.   

Sport England requests that changes be made or a supplementary note prepared to the Committee Report that reflects the matters raised above. Alternative, Sport Englnad would not object to this correspondence being shared with Committee Members.   Your acknowledgement of receipt of this email and an indication of how you wish to proceed would be most welcomed.   Yours sincerely Katy Walker Principal Planning Manager T: 020 7273 1906 E: katy.walker@sportengland.org Sport England's London office has moved to 1st Floor, 21 Bloomsbury Street, London, WC1B 3HF  

 Creating a sporting habit for life 

 

  

National Sports Centre, near Marlow, Buckinghamshire, SL7 1RR   

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.

This email has been scanned for email related threats and delivered safely by Mimecast. For more information please visit http://www.mimecast.com

Redbridge Local Plan 2015 - 2030 Preferred Options Extension Alternative Development Strategies Planning and Regeneration Service London Borough of Redbridge Freepost RSLR-JACE-HSUG Ilford IG1 1DD 17 December 2014 Dear John Pearce, Redbridge Local Plan 2015-2030 Preferred Options Report Extension – Alternative Development Strategies Thank you for inviting comment on the above document. The comments herein

represent the collective view of Sport England, the Football Association (FA) and

England and Wales Cricket Board (ECB).

Background The Government's National Planning Policy Framework (NPPF) is clear about the role that sport plays in delivering sustainable communities through promoting health and well-being. Paragraph 73 of the NPPF is quite clear:

“Access to high quality open spaces and opportunities for sport and recreation can make an important contribution to the health and well-being of communities. Planning policies should be based on robust and up to date assessments of the needs for open space, sports and recreation facilities and opportunities for new provision. The assessments should identify specific needs and quantitative or qualitative deficits or surpluses of open space, sports and recreational facilities in the local area. Information gained from the assessments should be used to determine what open space, sports and recreational provision is required.”

Paragraphs 70 and 74 of the NPPF also place great emphasis on the protection of existing sporting facilities:

[Para 70] “To deliver the social, recreational and cultural facilities and services the community needs, planning policies and decisions should:

guard against the unnecessary loss of valued facilities and services, particularly where this would reduce the community’s ability to meet its day-to-day needs”

[Para 74] “Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:

an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or

the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or

the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.”

In this context, local planning policy should aim to protect, enhance and provide for sports facilities based on robust and up-to-date assessments of need, as well as helping to realise the wider benefits that participation in sport can bring. Sound policy can only be developed in the context of objectively assessed needs, in turn used to inform the development of a strategy for sport and recreation. Policies which protect, enhance and provide for sports facilities should reflect this work, and be the basis for consistent application of policy in the h development management process. A strong local plan will only result from a clearly justified and positive approach to planning for sport. In this way, any local plan will be able to demonstrate that it has been positively prepared (based on objectively assessed needs), is consistent with national policy (reflecting the NPPF), is justified (having considered alternatives) and effective (being deliverable). Without such attention there is a significant risk that the local plan or other policy document could be considered unsound. It is in the context of the above, that Sport England, the FA and ECB make the following formal comments. Do you have any general comments on the planning challenges facing the Borough? It is clear from the Preferred Options consultation that LB of Redbridge face significant challenges in delivering its housing targets and planning strategically for housing growth. That said, The Government's NPPF puts great emphasis on, not only delivering housing growth, but delivering sustainable communities of which sport plays an important role. The opening paragraph in the ‘Forward’ of the Preferred Options consultation acknowledges that:

“…population growth is placing pressure on the borough’s social and environmental infrastructure, particularly housing, schools and leisure facilities.”

Despite the above acknowledgement and contrary to paragraph 73 of the NPPF, the Council has not sought to fully understand current and future needs for sport [leisure]. The draft Local Plan is not currently underpinned by a robust and up to date assessment of the needs for open space, sport and recreation facilities and therefore housing delivery is being considered in the absence of key information. As such, the role that sport plays in delivering sustainable communities has not been taken into account. This has resulted in two of the four preferred housing options, as set out in the Preferred Options consultation, involving the loss of existing playing field land.

It is understood that the Council has, in the last month, appointed a consultant to undertake a playing pitch strategy (PPS) for Redbridge. Whilst this is very much welcomed, this piece of work must be allowed to properly inform the Local Plan. In order for this to happen, the Local Plan review should ideally be halted until such time as this work has been undertaken. The findings and outcomes of the Strategy should be properly reviewed and fed into the Local Plan. Furthermore, it is likely that the findings of the PPS will likely necessitate a further review of the preferred options currently being consulted on. In this regard, the current consultation appears premature. As such, we would like the Council to consider the withdrawal of the current Preferred Options consultation and a redraft and re-consultation once the findings of the PPS have been properly considered and the preferred options reassessed in light of its findings. Without a robust and up to date assessment of the needs for sport having fed into and shaped the Local Plan from the outset, there is a risk that the Local Plan will be found to be unsound.

What do you think about Option 1 – proceed with Oakfields? Oakfields playing fields comprise twelve full size and nine junior size grass football pitches and four cricket grounds as well as two large pavilions which act as an inclusive social hub. The site is an important site not only to the residents of LB of Redbridge, but to those in surrounding London Boroughs, Essex and beyond who use the facility every week. Oakfields playing fields provide a high quality sport offer. The excellent playing facilities provide for upwards of 1,000 regularly players from age eight through to adult and is a key grassroots community hub for football and cricket. Sport England, The FA and the ECB strongly oppose the allocation of the Oakfields site for housing development. The allocation of this valuable and well used site for community sport is entirely contrary to Government policy, and in particular paragraphs 70, 73 and 74 of the NPPF. In considering the merits of Option 1 as a housing site, the Preferred Options consultation (page 16) states:

“…it is highly unlikely that the needs of current users such as the Old Parkonians Cricket and Football Clubs could continue to be accommodated. Nevertheless, following adoption of the revised Local Plan it would require detailed master planning and phasing before such a large project could commence. This time could be used to work with existing users with the aim of finding alternative land that met their needs.”

The above approach is not considered acceptable and fails to identify a suitable, deliverable named replacement site for sport. The role of the Local Plan is not simply to plan for the needs of housing, but to plan for all facility needs including sport, in delivering sustainable communities. Were the Local Plan to be underpinned by a robust and up to date assessment of the needs for sport then it would be possible to understand a) whether a replacement site even exists; b) its location; and c) how deliverable it may be. At this stage, this remains unknown. In any event, the Oakfields playing fields currently sit within the wider remit of sporting facilities which contribute to a locally important and significant sports hub environment.

The suggested disaggregation of this sustainable sports hub environment is not considered to be in the best interests of sport. What do you think about Option 2 – Find another site - increase the proposed development at land in and around Goodmayes and King George hospitals and the Ford Sports Ground in Seven Kings / Chadwell Heath? Options 2 comprises a number of individual sites in and around Goodmayes and King George hospitals and also including the Ford Sports Ground in Seven Kings. Page 18 of the Preferred Options consultation considers the allocation of the Ford Sports Ground in Seven Kings. It states:

“Apart from Seven Kings Park (which would need to be retained as protected open space), the only part of the site used for sport and recreation is the Ford Sports Ground. This is privately owned land. It is not open to the public and is less well used than when the Ford Motor Company was a major local employer.”

The above is the only reference to the Ford Sports Ground as a sport and recreation site within the consultation document. The above statement shows a lack of understanding of how the site is used and how it contributes to the wider sporting network of facilities. Again, without a robust and up to date assessment of the needs for sport, the importance of this site in delivering sporting outcomes has not been adequately taken into account. Ford Sports & Social ground comprises of seven full size grass football pitches, a small floodlit artificial pitch and a sports pavilion with car parking for more than 100 vehicles. Whilst privately owned the facilities are actively hired out to the local community for sport. During this current football season (2014/15) there are 13 grassroots football teams regularly using the site as its home ground for league fixtures including seven adult, three youth and three veteran teams. The site is recorded on Sport England Active Places database as community accessible sports ground open every day of the week until 10pm. As with Oakfield’s, this site has been allocated without due consideration being given to the importance of the site and the potential sporting impact of its loss. No reference has been made in Option 2 to the need to replace any playing field lost. The proposed allocation of the Ford Sports Ground in Seven Kings is opposed and is considered contrary to paragraphs 70, 73 and 74 of the NPPF As such, the inclusion of the Ford Sports Ground within Option 2 is not considered to be consistent with national policy or justified. What do you think about Option 3 – Western Corridor - Woodford Broadway / Woodford, South Woodford and Wanstead? There are no existing sports facilities or playing field on this site. Any development of this site will however, need to identify how and where the sporting needs arising from the development will be met either on site or offsite. The precise nature of these sporting needs should be identified and the relevant mechanism for their delivery should be included as part of any policy allocation of the site.

What do you think about Option 4 – Develop Green Belt land? Any land currently falling within the definition of a playing field or other land used for formal sport is not considered acceptable in principal for housing development. This principal applies equally to playing field or other land or buildings used for formal sport in the green belt. Overall, which option do you think is best for the borough and why?

The Council is strongly urged to consider the withdrawal of the current Preferred Options consultation and a redraft and re-consultation of this document once the findings of the Playing Pitch Strategy have been properly considered and the preferred options reassessed in light if its findings. Without a robust and up to date assessment of the needs for sport open space, sport and recreation facilities having fed into and shaped the Local Plan from the outset, there is a risk that the Local Plan will be found to be unsound. If the Council decide to progress with the Local Plan review in the absence of a robust and up to date assessment of the needs for sport, then Options 1 and 2 should be removed from further consideration as they would result in the unacceptable loss of playing field land and sports provision contrary to the provisions of paragraphs 70, 73 and 74 of the NPPF. In the absence of any robust needs and evidence base for sport, the Council is unable to understand and quantify the full impact of the loss of these facilities and thus its ability to develop sound and justified policy is severely hampered. As such, the continued allocation of either Oakfield’s (Option 1) or the Ford Sports Ground (part of Option 2) for housing development would be considered unsound and would be challenged by the sporting community at Examination in Public (EiP). We trust you will give the matters raised your fullest consideration.

Yours sincerely

Creating a sporting habit for life

BY EMIAL ONLY:

sola.odusina@redbridge.gov.uk

jon.simes@redbridge.gov.uk

carole.dungate@redbridge.gov.uk

01 October 2014

Dear Member,

Neighbourhoods and Communities Service Committee

Summary: The proposed allocation (for housing) of Oakfield’s playing field, which is a significant

and important playing field site locally, would not comply with paragraph 74 of the National

Planning Policy Framework. It is Sport England’s contention that the proposed allocation runs

contrary to the provisions of Paragraph 74 of the NPPF and any policy allocating this site for

housing is likely to be challenged by on grounds of soundness. The allocation of the site for

housing is not justified with reference to any up to date and robust evidence base in the form of

a playing pitch strategy.

As such, Sport England recommends that Cabinet Members reject proposals to allocate the

Oakfield’s playing field site for housing and ensure appropriate policy which protects what is an

important playing field serving the on-going needs of the sporting community.

Sport England is a statutory consultee on planning applications affecting playing field land.

Sport England aims to ensure positive planning for sport, enabling the right facilities to be

provided in the right places, based on robust and up-to-date assessments of need for all levels

of sport and all sectors of the community. To achieve this, our objectives are to seek to protect

sports facilities from loss as a result of redevelopment; to enhance existing facilities through

improving their quality, accessibility and management; and to provide new facilities that are fit

for purpose to meet demands for participation now and in the future.

Protecting, enhancing and providing opportunities to participate in sport is fundamental to

creating sustainable communities. The Government’s National Planning Policy Framework

(NPPF) makes the need for such consideration clear in its requirements to: deliver community

and cultural facilities to meet local needs; protect existing sports and recreational buildings and

land; guard against the unnecessary loss of valued facilities and services; and ensure that

decisions are based on robust, up-to-date and relevant evidence [my emphasis]

The Government's National Planning Policy Framework (NPPF) is clear about the role that sport

plays in delivering sustainable communities through promoting health and well-being. Sport

England, working with the provisions of the NPPF, wishes to see local planning policy protect,

enhance and provide for sports facilities based on robust and up-to-date assessments of need,

as well as helping to realise the wider benefits that participation in sport can bring. Sound

policy can only be developed in the context of objectively assessed needs, in turn used to

inform the development of a strategy for sport and recreation. Policies which protect, enhance

and provide for sports facilities should reflect this work, and be the basis for consistent

application through development management.

Creating a sporting habit for life

Sport England is not prescriptive on the precise form and wording of policies, but advises that a

stronger plan will result from attention to taking a clearly justified and positive approach to

planning for sport. In this way, planning authorities will be able to demonstrate that their plan

has been positively prepared (based on objectively assessed needs), is consistent with national

policy (reflecting the NPPF), is justified (having considered alternatives) and effective (being

deliverable). Without such attention there is a risk that a local plan or other policy document

could be considered unsound.

London Borough of Redbridge has no robust evidence in place relating to playing field

provision and despite Sport England’s efforts to date in advising that Redbridge undertake a

Playing Pitch Strategy, no such strategy is currently in place. Without a robust and up to date

Playing Pitch Strategy any loss of playing field land should be considered acceptable and policy

which seeks to allocate existing playing field land for housing will be opposed and challenged

on the grounds of soundness. Such a policy should not be found to be sound in the absence a

carefully quantified and documented assessment of current and future needs demonstrating

that there is an excess of playing field provision in the catchment, such that the Oakfield’s site

should legitimately be considered for housing development.

Paragraph 74 of the National Planning Policy Framework states:

Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:

• an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or

• the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or

• the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.

The proposed allocation (for housing) of Oakfield’s playing field, which is a significant and

important playing field site locally, would not comply with paragraph 74 of the NPPF above. It

is Sport England’s contention that the proposed allocation runs contrary to the provisions of

Paragraph 74 of the National Planning Policy Framework and any policy allocating this site for

housing is likely to be challenged by on grounds of soundness. The allocation of the site for

housing is not considered justifiable with reference to any up to date and robust evidence base

in the form of a playing pitch strategy.

As such, Sport England recommends that Cabinet Members reject proposals to allocate the

Oakfield’s playing field site for housing and ensure appropriate policy which protects what is an

important playing field serving the on-going needs of the sporting community.

If you would like any further information or advice please contact the undersigned at the

address below. Thank you for the opportunity to comment.

Yours Sincerely

Creating a sporting habit for life

Katy Walker

Planning Manager

Tel: 020 7273 1906

Email: katy.walker@sportengland.org

1

Carly Herod

Subject: FW: Redbridge Local Plan 2015-2030 Preferred OptionsAttachments: 20141217 LB Redbridge Local Plan Preferred Options Joint Response LET FINAL.pdf

 

From: Katy Walker [mailto:Katy.Walker@sportengland.org] Sent: 17 December 2014 14:27 To: DPD (Planning Service Area); John Pearce Cc: Laura Edwards Subject: Redbridge Local Plan 2015-2030 Preferred Options  Dear John Pearce,   Please find the attached formal representations in connection with the Redbridge Local Plan 2015‐2030 Preferred Options consultation.   The comments attached represent the collective view of Sport England, the Football Association (FA) and England and Wales Cricket Board (ECB).    Should you wish to discuss any of aspect of these representations, please contact me directly in the first instance.    We trust you will give the matters raised therein your fullest consideration and I look forward to receiving confirmation that the attached comments have been duly received and registered.   Yours sincerely Katy Walker Principal Planning Manager T: 020 7273 1906 E: katy.walker@sportengland.org 

 Creating a sporting habit for life 

 

   

Follow us on Twitter  Visit website  Sign up to our newsletter 

National Sports Centre, near Marlow, Buckinghamshire, SL7 1RR   

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.

This email has been scanned for email related threats and delivered safely by Mimecast. For more information please visit http://www.mimecast.com

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.

Redbridge Local Plan 2015 - 2030 Preferred Options Extension Alternative Development Strategies Planning and Regeneration Service London Borough of Redbridge Freepost RSLR-JACE-HSUG Ilford IG1 1DD 17 December 2014 Dear John Pearce, Redbridge Local Plan 2015-2030 Preferred Options Report Extension – Alternative Development Strategies Thank you for inviting comment on the above document. The comments herein

represent the collective view of Sport England, the Football Association (FA) and

England and Wales Cricket Board (ECB).

Background The Government's National Planning Policy Framework (NPPF) is clear about the role that sport plays in delivering sustainable communities through promoting health and well-being. Paragraph 73 of the NPPF is quite clear:

“Access to high quality open spaces and opportunities for sport and recreation can make an important contribution to the health and well-being of communities. Planning policies should be based on robust and up to date assessments of the needs for open space, sports and recreation facilities and opportunities for new provision. The assessments should identify specific needs and quantitative or qualitative deficits or surpluses of open space, sports and recreational facilities in the local area. Information gained from the assessments should be used to determine what open space, sports and recreational provision is required.”

Paragraphs 70 and 74 of the NPPF also place great emphasis on the protection of existing sporting facilities:

[Para 70] “To deliver the social, recreational and cultural facilities and services the community needs, planning policies and decisions should:

guard against the unnecessary loss of valued facilities and services, particularly where this would reduce the community’s ability to meet its day-to-day needs”

[Para 74] “Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:

an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or

the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or

the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.”

In this context, local planning policy should aim to protect, enhance and provide for sports facilities based on robust and up-to-date assessments of need, as well as helping to realise the wider benefits that participation in sport can bring. Sound policy can only be developed in the context of objectively assessed needs, in turn used to inform the development of a strategy for sport and recreation. Policies which protect, enhance and provide for sports facilities should reflect this work, and be the basis for consistent application of policy in the h development management process. A strong local plan will only result from a clearly justified and positive approach to planning for sport. In this way, any local plan will be able to demonstrate that it has been positively prepared (based on objectively assessed needs), is consistent with national policy (reflecting the NPPF), is justified (having considered alternatives) and effective (being deliverable). Without such attention there is a significant risk that the local plan or other policy document could be considered unsound. It is in the context of the above, that Sport England, the FA and ECB make the following formal comments. Do you have any general comments on the planning challenges facing the Borough? It is clear from the Preferred Options consultation that LB of Redbridge face significant challenges in delivering its housing targets and planning strategically for housing growth. That said, The Government's NPPF puts great emphasis on, not only delivering housing growth, but delivering sustainable communities of which sport plays an important role. The opening paragraph in the ‘Forward’ of the Preferred Options consultation acknowledges that:

“…population growth is placing pressure on the borough’s social and environmental infrastructure, particularly housing, schools and leisure facilities.”

Despite the above acknowledgement and contrary to paragraph 73 of the NPPF, the Council has not sought to fully understand current and future needs for sport [leisure]. The draft Local Plan is not currently underpinned by a robust and up to date assessment of the needs for open space, sport and recreation facilities and therefore housing delivery is being considered in the absence of key information. As such, the role that sport plays in delivering sustainable communities has not been taken into account. This has resulted in two of the four preferred housing options, as set out in the Preferred Options consultation, involving the loss of existing playing field land.

It is understood that the Council has, in the last month, appointed a consultant to undertake a playing pitch strategy (PPS) for Redbridge. Whilst this is very much welcomed, this piece of work must be allowed to properly inform the Local Plan. In order for this to happen, the Local Plan review should ideally be halted until such time as this work has been undertaken. The findings and outcomes of the Strategy should be properly reviewed and fed into the Local Plan. Furthermore, it is likely that the findings of the PPS will likely necessitate a further review of the preferred options currently being consulted on. In this regard, the current consultation appears premature. As such, we would like the Council to consider the withdrawal of the current Preferred Options consultation and a redraft and re-consultation once the findings of the PPS have been properly considered and the preferred options reassessed in light of its findings. Without a robust and up to date assessment of the needs for sport having fed into and shaped the Local Plan from the outset, there is a risk that the Local Plan will be found to be unsound.

What do you think about Option 1 – proceed with Oakfields? Oakfields playing fields comprise twelve full size and nine junior size grass football pitches and four cricket grounds as well as two large pavilions which act as an inclusive social hub. The site is an important site not only to the residents of LB of Redbridge, but to those in surrounding London Boroughs, Essex and beyond who use the facility every week. Oakfields playing fields provide a high quality sport offer. The excellent playing facilities provide for upwards of 1,000 regularly players from age eight through to adult and is a key grassroots community hub for football and cricket. Sport England, The FA and the ECB strongly oppose the allocation of the Oakfields site for housing development. The allocation of this valuable and well used site for community sport is entirely contrary to Government policy, and in particular paragraphs 70, 73 and 74 of the NPPF. In considering the merits of Option 1 as a housing site, the Preferred Options consultation (page 16) states:

“…it is highly unlikely that the needs of current users such as the Old Parkonians Cricket and Football Clubs could continue to be accommodated. Nevertheless, following adoption of the revised Local Plan it would require detailed master planning and phasing before such a large project could commence. This time could be used to work with existing users with the aim of finding alternative land that met their needs.”

The above approach is not considered acceptable and fails to identify a suitable, deliverable named replacement site for sport. The role of the Local Plan is not simply to plan for the needs of housing, but to plan for all facility needs including sport, in delivering sustainable communities. Were the Local Plan to be underpinned by a robust and up to date assessment of the needs for sport then it would be possible to understand a) whether a replacement site even exists; b) its location; and c) how deliverable it may be. At this stage, this remains unknown. In any event, the Oakfields playing fields currently sit within the wider remit of sporting facilities which contribute to a locally important and significant sports hub environment.

The suggested disaggregation of this sustainable sports hub environment is not considered to be in the best interests of sport. What do you think about Option 2 – Find another site - increase the proposed development at land in and around Goodmayes and King George hospitals and the Ford Sports Ground in Seven Kings / Chadwell Heath? Options 2 comprises a number of individual sites in and around Goodmayes and King George hospitals and also including the Ford Sports Ground in Seven Kings. Page 18 of the Preferred Options consultation considers the allocation of the Ford Sports Ground in Seven Kings. It states:

“Apart from Seven Kings Park (which would need to be retained as protected open space), the only part of the site used for sport and recreation is the Ford Sports Ground. This is privately owned land. It is not open to the public and is less well used than when the Ford Motor Company was a major local employer.”

The above is the only reference to the Ford Sports Ground as a sport and recreation site within the consultation document. The above statement shows a lack of understanding of how the site is used and how it contributes to the wider sporting network of facilities. Again, without a robust and up to date assessment of the needs for sport, the importance of this site in delivering sporting outcomes has not been adequately taken into account. Ford Sports & Social ground comprises of seven full size grass football pitches, a small floodlit artificial pitch and a sports pavilion with car parking for more than 100 vehicles. Whilst privately owned the facilities are actively hired out to the local community for sport. During this current football season (2014/15) there are 13 grassroots football teams regularly using the site as its home ground for league fixtures including seven adult, three youth and three veteran teams. The site is recorded on Sport England Active Places database as community accessible sports ground open every day of the week until 10pm. As with Oakfield’s, this site has been allocated without due consideration being given to the importance of the site and the potential sporting impact of its loss. No reference has been made in Option 2 to the need to replace any playing field lost. The proposed allocation of the Ford Sports Ground in Seven Kings is opposed and is considered contrary to paragraphs 70, 73 and 74 of the NPPF As such, the inclusion of the Ford Sports Ground within Option 2 is not considered to be consistent with national policy or justified. What do you think about Option 3 – Western Corridor - Woodford Broadway / Woodford, South Woodford and Wanstead? There are no existing sports facilities or playing field on this site. Any development of this site will however, need to identify how and where the sporting needs arising from the development will be met either on site or offsite. The precise nature of these sporting needs should be identified and the relevant mechanism for their delivery should be included as part of any policy allocation of the site.

What do you think about Option 4 – Develop Green Belt land? Any land currently falling within the definition of a playing field or other land used for formal sport is not considered acceptable in principal for housing development. This principal applies equally to playing field or other land or buildings used for formal sport in the green belt. Overall, which option do you think is best for the borough and why?

The Council is strongly urged to consider the withdrawal of the current Preferred Options consultation and a redraft and re-consultation of this document once the findings of the Playing Pitch Strategy have been properly considered and the preferred options reassessed in light if its findings. Without a robust and up to date assessment of the needs for sport open space, sport and recreation facilities having fed into and shaped the Local Plan from the outset, there is a risk that the Local Plan will be found to be unsound. If the Council decide to progress with the Local Plan review in the absence of a robust and up to date assessment of the needs for sport, then Options 1 and 2 should be removed from further consideration as they would result in the unacceptable loss of playing field land and sports provision contrary to the provisions of paragraphs 70, 73 and 74 of the NPPF. In the absence of any robust needs and evidence base for sport, the Council is unable to understand and quantify the full impact of the loss of these facilities and thus its ability to develop sound and justified policy is severely hampered. As such, the continued allocation of either Oakfield’s (Option 1) or the Ford Sports Ground (part of Option 2) for housing development would be considered unsound and would be challenged by the sporting community at Examination in Public (EiP). We trust you will give the matters raised your fullest consideration.

Yours sincerely