Example: South Cambridgeshire
The South Cambridgeshire DC Policies DPD has now been submitted to the Secretary of State. Policy SF/10 requires all residential development to contribute towards formal outdoor sports facilities and Policy SF/9 protects existing recreation areas and is similar to our playing fields policy. However, Sport England objected to policy SF/10 on the basis that it only applies to residential developments and that it does not include provision for contributions to be made to built sports facilities. The objections to this policy, based on a perceived failure to pass the soundness tests set out in PPS12 and the Planning Inspectorate's guidance, are set out below.
Policy SF10 – Submission Draft Development Control Policies DPD (Outdoor Playspace and New Developments)
Policy SF/10 of the Submission Draft Development Control Policies DPD (Outdoor Playspace and New Developments) is objected to because it appears to apply only to residential developments as no reference is made to other developments making provision for open space and sports facilities. Reference should be made in the policy to other development such as employment making provision for open space and sports facilities where appropriate.
Explanation and Justification of Objection
The tests of soundness that this objection relates are conformity (consistency with national planning policy) and coherence, consistency and effectiveness (consistency within DPDs and flexibility to enable the plan to deal with changing circumstances) for the reasons set out below.
Paragraph 23 of PPG17 (Planning for Open Space, Sport and Recreation - 2002) advises local authorities to ensure that provision is made for local sport and recreation facilities where planning permission is granted for new developments (especially housing). Whilst the guidance in PPG17 indicates that such provision should especially be made in relation to housing developments, it is not exclusive to such developments. Furthermore, policy DP/4 of the Development Control Policies DPD which provides guidance on infrastructure and new development identifies open space, sport and recreation in a list of infrastructure that developments may be required to make contributions towards. However, this policy does not confirm that such contributions will be restricted to residential development.
Non-residential developments, particularly employment developments can place pressures on existing sport and recreation facilities as workers will use facilities before, during and after working hours. Swimming pools, sports halls and health and fitness facilities are particularly popular with workers. The new employment developments at Northstowe and Cambridge East for instance, may be large enough to justify the provision of open space and sports facilities to meet the needs of workers. Furthermore, any new or expanded business park proposals in the district may generate additional demand for such facilities. If the impact of major non-residential developments on sport and recreation facility provision is not adequately considered (and no additional provision is made), this can result in additional pressures being placed on nearby facilities provided for the residential population (which may already have exceeded their capacity) and can generate increased travel movements by car (e.g. workers driving out of employment areas to visit health and fitness clubs in town centre/residential areas during their lunch break). The provision of amenity space as part of landscaping schemes associated with new employment areas would be insufficient for addressing such needs.
The Major Sports Facility Strategy for the Cambridge Sub-Region that is currently being prepared may identify sports facility needs associated with existing or proposed employment, health or other non-residential developments. Policy SF/10 in its current form would not be sufficiently flexible to seek sport and recreation facility provision (or contributions in lieu of on-site provision) from non-residential developments if this strategy identified a need for such provision. As this policy has been prepared in advance of the findings of the Major Sports Facility Strategy for the Cambridge Sub-Region it may not be sufficiently flexible to address changing circumstances.
It is advised that the provision of sport and recreation facilities associated with non-residential development is established in development plan policy elsewhere. Other local authorities have established local plan policies and/or SPG which require contributions to made from employment developments based on the net additional floorspace provided and have been successful in securing such provision. e.g. Windsor & Maidenhead, Kettering, Chesterfield.
It is considered that changing the plan to seek open space and sport/recreation provision in non-residential developments would improve the soundness of the DPD as it would allow greater consistency with Government planning guidance (PPG17) and greater consistency within the document (with policy DP/4). This change would also provide greater flexibility to address changing circumstances e.g. the implications of the Major Sports Facility Strategy. The sustainability of the plan would also be improved as more potential would exist for the impact of development on community infrastructure (open space and sport/recreation) to be mitigated when development proposals are considered. Without such a change, the additional demands that may be generated for community infrastructure by new developments may not be met which would not be consistent with sustainable development principles
Change to the Plan
To address this objection, section 1 of policy SF/10 should be amended to add “Where appropriate, non-residential developments will be required to contribute to Outdoor Playing Space, Informal Open Space and Strategic Open Space.” A new paragraph should then be added to the reasoned justification which explains the rationale for seeking provision in non-residential developments and provides examples of where it may be appropriate for provision to be made e.g. new business parks, employment areas in major new developments etc. The Recreation and Community SPD should then set out implementation mechanisms for this type of provision in accordance with paragraph 6.16. |
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