Comment
Draft Regulation 18 Sandwell Local Plan
Representation ID: 810
Received: 14/12/2023
Respondent: Sport England
Sport England notes that appendix J seeks to extract the headline findings and recommendations of the PPOSS Strategy and Action Plan (parts 4 & 6).
We have two concerns with the approach taken. Firstly, the Local Plan will have a much longer timespan that the PPOSS. The PPOSS will need to be reviewed and replaced within 3-5 years in order to maintain a robust and up to date evidence base in line with para 98 of the NPPF and in accordance with Sport England's Playing Fields Guidance. As such the extracted data in Appendix J is likely to become out of date in due course given that lifespan of the Development Plan, once adopted.
Secondly, there is a danger that by extracting some information from the PPOSS document, and summarising or para-phrasing parts of it that the reader is mis-directed to the relevant evidence. Whilst the first table entitled "Pitch Sports - Quantitative headline findings" replicates the respective table in the PPOSS, the table entitled "Recommendations for future provision" is a much edited version of the relevant section of the PPOSS report, and thereby includes certain findings and recommendations and omits others. We have concern that by cherry picking certain recommendations from the PPOSS that this mis-represents the recommendations as a whole.
We would recommend that Appendix J be removed so that the reader is instead referred to the PPOSS itself which is included as part of the Council's evidence base on the website.
Sport England notes that appendix J seeks to extract the headline findings and recommendations of the PPOSS Strategy and Action Plan (parts 4 & 6).
We have two concerns with the approach taken. Firstly, the Local Plan will have a much longer timespan that the PPOSS. The PPOSS will need to be reviewed and replaced within 3-5 years in order to maintain a robust and up to date evidence base in line with para 98 of the NPPF and in accordance with Sport England's Playing Fields Guidance. As such the extracted data in Appendix J is likely to become out of date in due course given that lifespan of the Development Plan, once adopted.
Secondly, there is a danger that by extracting some information from the PPOSS document, and summarising or para-phrasing parts of it that the reader is mis-directed to the relevant evidence. Whilst the first table entitled "Pitch Sports - Quantitative headline findings" replicates the respective table in the PPOSS, the table entitled "Recommendations for future provision" is a much edited version of the relevant section of the PPOSS report, and thereby includes certain findings and recommendations and omits others. We have concern that by cherry picking certain recommendations from the PPOSS that this mis-represents the recommendations as a whole.
We would recommend that Appendix J be removed so that the reader is instead referred to the PPOSS itself which is included as part of the Council's evidence base on the website.