3 letters from SE to WBC planning:
Sent: 10 September 2018 11:33
To: ‘email@example.com’ <firstname.lastname@example.org>
Subject: App Ref: 18/02046/DEMO – Faraday Road Stadium – Sport England
FAO J Singh
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
Sport England has considered the application in light of the
National Planning Policy Framework (particularly Para 97) and Sport England’s
Playing Fields Policy, which is presented within its ‘Playing Fields Policy and
Guidance Document’: 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
This an application for prior notification for demolition of
Assessment against Sport England Policy/NPPF
Without the stand, football cannot be played on this site at the
level it is currently able to be played, therefore the application prejudices
the use of the playing field.
I am also concerned that the applicants have
not linked this application to applications 18/00604/OUT and 18/00603/COMIND, which deal with the redevelopment of the whole site.
I would draw your attention in particular to
our responses to both these previous applications (which I have attached) where we require that details
of the re-provision of the facilities are submitted prior to any redevelopment
of the site.
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 97 of the NPPF.
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
To overcome our objection, this application should be linked/make
reference to planning applications 18/00604/OUT and 18/00603/COMIND and have
the same conditions about details of the replacement provision attached to the
you would like any further information or advice please contact me at the
Bob Sharples RIBA MRTPI
Principal Planning Manager – South Planning Team
FAO J Singh Esq.
Thank you for consulting Sport England on the
above named application.
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
- 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:
This is an outline planning application follows
the application submitted in April this year for the renewal and expansion
of existing football pitch including artificial pitches, application number
18/00603/COMIND, which is currently awaiting a decision.
What is being applied for in this application
is outline consent for the replacement of clubhouse and stand at Newbury
Football Ground. Matters to be considered: Access and Layout.
The Football Association and the Football
Foundation are supportive of this proposal.
Having assessed the application, Sport England
is satisfied that the proposed development should meet exception 2 of our
playing fields policy, in that:
‘The proposed development is for ancillary
facilities supporting the principal use of the site as a playing field, and
does not affect the quantity or quality of playing pitches or otherwise
adversely affect their use.’
As the proposal is an outline application there
are insufficient details to ensure that the clubhouse meets the standards
required by the football league. This can be addressed by a suitable
condition to ensure the design and layout are acceptable, in order to meet our
planning policy exception E2. This would remove any doubt.
However, this application cannot be implemented
without 18/00603/COMIND being implemented. While this may seem common
sense, it is the view of the Football Association, the Football Foundation and
Sport England that there needs to be a condition to ensure that neither
application can be implemented independently. This is in line with
condition 2 which my colleague Vicky Aston recommended in her response to
18/00603/COMIND on the 10th May 2018.
Given the above assessment, Sport England does
not wish to raise an objection to this application subject to the following
- No development shall commence until further details of
the design and layout of the clubhouse and stand have been submitted to
and approved in writing by the Local Planning Authority after consultation
with Sport England. The pitches shall not be constructed other than in
accordance with the approved details.
Reason: To ensure the
development is fit for purpose and sustainable and to accord with Development
Plan Policy **.
- No development shall commence until details for the
phasing of the development, including the re-provision of the new
full-size 3G Artificial Grass Pitch, a junior pitch and 2 mini pitches,
have been submitted to and approved in writing by the Local Planning
Authority after consultation with Sport England. The development hereby
permitted shall not be carried out other than in accordance with the
ensure the satisfactory quantity, quality and accessibility of the ancillary
facilities (clubhouse and stand) which secures a continuity of use and to
accord with Development Plan Policy **.
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 the undersigned at the address below.
Bob Sharples RIBA MRTPI
Principal Planning Manager – South
T: 07830 315030
F: 01509 233 192