Local Plan 2036: Issues and Options Stage

Document Section 1. North Somerset Local Plan 2036: Issues and Options Document Potential new policy areas Q54. Are there any other policy areas you feel need to be considered – either new policies, or amendments to an existing policy? [View all comments on this section]
Comment ID 8126849//1
Respondent Sport England [View all comments by this respondent]
Response Date 16 Jan 2019

Thank you for consulting Sport England on the above Local Plan Issues & Options document for the plan period up to 2036.

Sport England is the Government agency responsible for delivering the Government’s sporting objectives. Maximising the investment into sport and recreation through the land use planning system is one of our priorities. You will also be aware that Sport England is a statutory consultee on planning applications affecting playing fields.

The new Sport England Strategy ‘Towards An Active Nation’ (2016-21) identifies key changes in the delivery of the strategy:

  • Tackle inactivity: more money and resources
  • Invest in children and young people to build positive attitudes to sport and activity
  • Help those currently active to carry on, but at a lower cost to the public purse
  • Put customers at the heart of what we do/be welcoming and inclusive
  • Help sport to keep pace with the digital expectations of customers
  • Encourage stronger local collaboration to deliver a joined up experience for customers
  • Working with a wide range of partners, using our expertise and investment to align
  • Applying behaviour change principles to encourage innovation to share best practice
  • Sport England has assessed this consultation in the light of Sport England’s Planning for Sport: Forward Planning guidance http://www.sportengland.org/facilities-planning/planning-for-sport/

The overall thrust of the statement is that a planned approach to the provision of facilities and opportunities for sport is necessary, new sports facilities should be fit for purpose, and they should be available for community sport. To achieve this, our objectives are to:

PROTECT sports facilities from loss as a result of redevelopment

ENHANCE existing facilities through improving their quality, accessibility and management

PROVIDE new facilities that are fit for purpose to meet demands for participation now and in the future.


Sport England believes that sport has an important role in modern society and in creating sustainable and healthy communities. Sport and physical activity is high on the Government’s national agenda as it cuts across a number of current topics that include health, social inclusion, regeneration and anti social behaviour. The importance of sport should be recognised as a key component of development plans, and not considered in isolation.


The following comments are provided within the context of:


• The National Planning Policy Framework (DCLG, 2018).

• Sport England’s Planning for Sport webpages (2018).

  • Economic Value of Sport


In terms of the economic value of sport, Sport England has developed a tool that can demonstrate how sport benefits the local economy http://www.sportengland.org/research/benefits-of-sport/economic-value-of-sport/ The model produces area based estimates on sports’ contribution to the local economy in the form of a business output gross value added (GVA) and jobs plus wider benefits like health. Using the weblink above you can register to use the tool and access the guidance notes including FAQs.


Summary - using level 1 basic snapshot of the tool (automatically generated overall view of the local sport economy indicating the contribution made by businesses and services supporting people playing sport plus the wider interests in sport):

  • Total Direct Economic Value for Sport - £56.5 million
  • Of which Participation in Sport - £43.5 million
  • The wider economic value to health is £82.6 million although not directly linked to total direct value of sport. Please refer to the FAQs on the website.

BaNES £m

Bristol £m

N Somerset £m

S Glos £m


Total Direct Economic Value for Sport






Of which Participation in Sport






The wider economic value to health








  1. Local Plan & Evidence Base

The National Planning Policy Framework (DCLG, 2018) states:

  1. Access to a network of high quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities. Planning policies should be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision. Information gained from the assessments should be used to determine what open space, sport and  recreational provision is needed, which plans should then seek to accommodate.

Sport England’s view is that, in order to meet the requirements of the National Planning Policy Framework (NPPF), this should include a strategy (supply and demand analysis with qualitative issues included) covering the need for indoor and outdoor sports facilities, including playing pitches.

We raise concern that there does not appear to be a robust and up to date evidence base for sport and recreation in North Somerset. We are, however, aware that the Council’s Leisure Team are working on a Playing Pitch Strategy and Built Facilities Strategy.


  1. Planning Obligations/Community Infrastructure Levy (CIL) to Sport

Sport England supports use of planning obligations (s106)/community infrastructure levy (CIL) as a way of securing the provision of new or enhanced places for sport and a contribution towards their future maintenance, to meet the needs arising from new development. This does need to be based on a robust NPPF evidence base. This includes indoor sports facilities (swimming pools, sports halls, etc) as well as playing fields and multi use games courts.

All new dwellings in North Somerset in the plan period should provide for new or enhance existing sport and recreation facilities to help create opportunities for physical activity whilst having a major positive impact on health and mental wellbeing.

This includes the 4 key proposed housing sites:

Backwell 700 homes

Banwell Garden Village 1900 homes

Mendip Spring Garden Village at Churchill 2675 homes

Nailsea 2575 homes

The evidence base as mentioned in (2) above should inform the Infrastructure Delivery Plan (IDP) and / or CIL Reg 123 list. We all need to be mindful of s106 regulations that restrict up to 5 schemes contributing to a single project. There maybe changes to those regulations in the future including the withdrawal for the need of a 123 list.

  1. 4. Protection of Sport & Recreation including playing fields

Sport England acknowledges that the NPPF is promoting “sustainable development” to avoid delays in the planning process (linked to economic growth). Thatsaid, the NPPF also says that for open space, sport & recreation land & buildings (including playing fields):

  1. Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:
  2. a)  an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or
  3. b)  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
  4. c)  the development is for alternative sports and recreational provision, the benefits of which clearly outweigh the loss of the current or former use.

Sport England would be very concerned if any existing sport & recreation land & buildings including playing pitches would be affected by these proposals without adequate replacement in terms of quality, quantity, accessibility, management & maintenance and prior to the loss of the existing facility.  This includes the major development proposal that could have an negative impact on Churchill Cricket Club in the planned Mendip Spring Garden Village proposal of 2675 homes.

Sport England considers proposals affecting playing fields in light of the National Planning Policy Framework (NPPF) (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:


Sport England strategy Towards an Active Nation identifies a planned approach to provision of facilities and opportunities for sport is necessary - protect and enhance existing and provide new facilities. Sport is a key component of plans and shouldn't be considered in isolation. Sport benefits the local economy. Does not appear to be a robust and up-to-date evidence base for sport and recreation in North Somerset. Needed to inform IDP and CIL. Need adequate replacement of affected facilities.