Draft Regulation 18 Sandwell Local Plan

SH3 (SA21) 88-90 Dudley Road West - The proposed allocation for housing would lead to the loss of an existing indoor cricket facility for which para 99 of the NPPF and draft policy SHW5 would apply. No reference is made to mitigating the loss of this existing sports facility or demonstrating it is surplus in accordance with these relevant policies. Sport England therefore objects to the proposed allocation, and would recommend that either the allocation be deleted from the plan, or be revised so as to ensure the sports facility is retained, or that additional text be added to make it clear that the proposed allocation can only come forward subject to addressing the loss of the facility in line with the above policies.

SH9 (SA28) The Phoenix Collegiate, Friar Park Road, Wednesbury - Notwithstanding that the site has an existing outline planning consent for residential development, this is subject to a section 106 agreement to secure mitigation for the loss of existing playing fields. The planning consent whilst still extant has not been implemented. It is important to recognise that the site contains existing playing fields, the loss of which would need to be mitigated in line with para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Field Policy and Guidance. As drafted the allocation does not address this and so Sport England raises an objection to the proposed allocation. To address this, the allocation wording should reference the need to mitigate the loss of playing field.

SH18 (SA55) Friar Park (STW/SMBC land), Wednesbury - Sport England recognises that the allocation does make reference to mitigating the loss of playing pitches in line with the PPOSS/Action Plan, but objects to this being subject to viability testing, since there is no relevant exception criteria for viability testing in para 99 of the NPPF, nor within draft policy SHW5, nor within Sport England's Playing Fields Policy and Guidance. To address, this we recommend that the reference to viability testing be removed.

SH34 (SA79) Brandhall Golf Course - The allocation references an existing planning application for redevelopment of the site, for which Sport England have objected. We recognise that there is no longer a need to retain the 18 hole municipal course, but take the view that mitigation should be secured to make qualitative improvements to the existing golf course facility at Warley Woods in line with the findings and recommendations of the PPOSS 2022. We understand that a planning condition has been included to secure this mitigation. To address this, we would recommend that an appropriate reference be added to the allocation regarding securing an appropriate the off-site contribution towards golf.

SH40 (SA94) Langley Swimming Centre, Vicarage Road, Oldbury - This existing Leisure Centre site contains two swimming pools and a health and fitness centre. The facility closed in July 2023 when the Sandwell Aquatics Centre opened for public use. The SAC provides equitable or better facilities in both quantity and quality , and is in a suitable location, in line with para 99 of the NPPF, and so Sport England has no objection to the loss of this site to sport.

SH43 (SA166) Land off Tanhouse Avenue, Great Barr - The site includes an area of disused playing field that has previously been delineated to provide a football pitch. The proposed allocation does not reference this, and does not identify the need to mitigate the loss of the playing field in line with para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Fields Policy, and so we object to this proposed allocation. To address this, either the proposed allocation should be deleted, or additional text be added to make it clear that the proposed allocation an only come forward subject to addressing the loss of former playing field in line with the above policies.

SM2 (SA199) Lion Farm, Oldbury - The site constitutes existing playing field for which para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Fields Policy apply. Sport England notes the allocation is for retention of 6 sports pitches with changing facilities and car parking (5 ha), with the remainder to be lost to a mix of residential, employment and open space uses. We note the reference that this allocation is strongly caveated by the ability to relocate 6 pitches to the southern part of the Borough, however this does not provide sufficient comfort that a proposal will come forward to provide replacement playing field that is equivalent or better quantity, equivalent or better quality, in a suitable location, and subject to equivalent or better accessibility and management arrangements to meet the relevant Exception criteria of our policy. The Council's own evidence base in the PPOSS 2022 identifies shortfalls of capacity for football in Oldbury and across the Borough, both now and in the future, with a recommendation to protect and enhance the quality of the existing pitches at Lion Farm. The site is well used for adult league football in the Warley Sunday League by several local teams whose demand would likely be displaced should the site be redeveloped. Sport England are aware that finding a suitable site(s) to replace 6 pitches will be extremely challenging for the Council in light of the findings and recommendations of the PPOSS, and so in the absence of detailed deliverable proposals that demonstrate how these pitches would be replaced in line with the relevant policies referred to above, Sport England is of the view that there is significant doubt that the caveat would be reasonably met. We consider this allocation to be in direct conflict with the Council's stated ambitions, vision and objectives of the Draft Plan, particularly those that seek to improve the health and well-being of Borough's residents. As such, Sport England strongly objects to the proposed allocation which should be removed from the plan.

SH3 (SA21) 88-90 Dudley Road West - The proposed allocation for housing would lead to the loss of an existing indoor cricket facility for which para 99 of the NPPF and draft policy SHW5 would apply. No reference is made to mitigating the loss of this existing sports facility or demonstrating it is surplus in accordance with these relevant policies. Sport England therefore objects to the proposed allocation, and would recommend that either the allocation be deleted from the plan, or be revised so as to ensure the sports facility is retained, or that additional text be added to make it clear that the proposed allocation can only come forward subject to addressing the loss of the facility in line with the above policies.

SH9 (SA28) The Phoenix Collegiate, Friar Park Road, Wednesbury - Notwithstanding that the site has an existing outline planning consent for residential development, this is subject to a section 106 agreement to secure mitigation for the loss of existing playing fields. The planning consent whilst still extant has not been implemented. It is important to recognise that the site contains existing playing fields, the loss of which would need to be mitigated in line with para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Field Policy and Guidance. As drafted the allocation does not address this and so Sport England raises an objection to the proposed allocation. To address this, the allocation wording should reference the need to mitigate the loss of playing field.

SH18 (SA55) Friar Park (STW/SMBC land), Wednesbury - Sport England recognises that the allocation does make reference to mitigating the loss of playing pitches in line with the PPOSS/Action Plan, but objects to this being subject to viability testing, since there is no relevant exception criteria for viability testing in para 99 of the NPPF, nor within draft policy SHW5, nor within Sport England's Playing Fields Policy and Guidance. To address, this we recommend that the reference to viability testing be removed.

SH34 (SA79) Brandhall Golf Course - The allocation references an existing planning application for redevelopment of the site, for which Sport England have objected. We recognise that there is no longer a need to retain the 18 hole municipal course, but take the view that mitigation should be secured to make qualitative improvements to the existing golf course facility at Warley Woods in line with the findings and recommendations of the PPOSS 2022. We understand that a planning condition has been included to secure this mitigation. To address this, we would recommend that an appropriate reference be added to the allocation regarding securing an appropriate the off-site contribution towards golf.

SH40 (SA94) Langley Swimming Centre, Vicarage Road, Oldbury - This existing Leisure Centre site contains two swimming pools and a health and fitness centre. The facility closed in July 2023 when the Sandwell Aquatics Centre opened for public use. The SAC provides equitable or better facilities in both quantity and quality , and is in a suitable location, in line with para 99 of the NPPF, and so Sport England has no objection to the loss of this site to sport.

SH43 (SA166) Land off Tanhouse Avenue, Great Barr - The site includes an area of disused playing field that has previously been delineated to provide a football pitch. The proposed allocation does not reference this, and does not identify the need to mitigate the loss of the playing field in line with para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Fields Policy, and so we object to this proposed allocation. To address this, either the proposed allocation should be deleted, or additional text be added to make it clear that the proposed allocation an only come forward subject to addressing the loss of former playing field in line with the above policies.

SM2 (SA199) Lion Farm, Oldbury - The site constitutes existing playing field for which para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Fields Policy apply. Sport England notes the allocation is for retention of 6 sports pitches with changing facilities and car parking (5 ha), with the remainder to be lost to a mix of residential, employment and open space uses. We note the reference that this allocation is strongly caveated by the ability to relocate 6 pitches to the southern part of the Borough, however this does not provide sufficient comfort that a proposal will come forward to provide replacement playing field that is equivalent or better quantity, equivalent or better quality, in a suitable location, and subject to equivalent or better accessibility and management arrangements to meet the relevant Exception criteria of our policy. The Council's own evidence base in the PPOSS 2022 identifies shortfalls of capacity for football in Oldbury and across the Borough, both now and in the future, with a recommendation to protect and enhance the quality of the existing pitches at Lion Farm. The site is well used for adult league football in the Warley Sunday League by several local teams whose demand would likely be displaced should the site be redeveloped. Sport England are aware that finding a suitable site(s) to replace 6 pitches will be extremely challenging for the Council in light of the findings and recommendations of the PPOSS, and so in the absence of detailed deliverable proposals that demonstrate how these pitches would be replaced in line with the relevant policies referred to above, Sport England is of the view that there is significant doubt that the caveat would be reasonably met. We consider this allocation to be in direct conflict with the Council's stated ambitions, vision and objectives of the Draft Plan, particularly those that seek to improve the health and well-being of Borough's residents. As such, Sport England strongly objects to the proposed allocation which should be removed from the plan.

SH3 (SA21) 88-90 Dudley Road West - The proposed allocation for housing would lead to the loss of an existing indoor cricket facility for which para 99 of the NPPF and draft policy SHW5 would apply. No reference is made to mitigating the loss of this existing sports facility or demonstrating it is surplus in accordance with these relevant policies. Sport England therefore objects to the proposed allocation, and would recommend that either the allocation be deleted from the plan, or be revised so as to ensure the sports facility is retained, or that additional text be added to make it clear that the proposed allocation can only come forward subject to addressing the loss of the facility in line with the above policies.

SH9 (SA28) The Phoenix Collegiate, Friar Park Road, Wednesbury - Notwithstanding that the site has an existing outline planning consent for residential development, this is subject to a section 106 agreement to secure mitigation for the loss of existing playing fields. The planning consent whilst still extant has not been implemented. It is important to recognise that the site contains existing playing fields, the loss of which would need to be mitigated in line with para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Field Policy and Guidance. As drafted the allocation does not address this and so Sport England raises an objection to the proposed allocation. To address this, the allocation wording should reference the need to mitigate the loss of playing field.

SH18 (SA55) Friar Park (STW/SMBC land), Wednesbury - Sport England recognises that the allocation does make reference to mitigating the loss of playing pitches in line with the PPOSS/Action Plan, but objects to this being subject to viability testing, since there is no relevant exception criteria for viability testing in para 99 of the NPPF, nor within draft policy SHW5, nor within Sport England's Playing Fields Policy and Guidance. To address, this we recommend that the reference to viability testing be removed.

SH34 (SA79) Brandhall Golf Course - The allocation references an existing planning application for redevelopment of the site, for which Sport England have objected. We recognise that there is no longer a need to retain the 18 hole municipal course, but take the view that mitigation should be secured to make qualitative improvements to the existing golf course facility at Warley Woods in line with the findings and recommendations of the PPOSS 2022. We understand that a planning condition has been included to secure this mitigation. To address this, we would recommend that an appropriate reference be added to the allocation regarding securing an appropriate the off-site contribution towards golf.

SH40 (SA94) Langley Swimming Centre, Vicarage Road, Oldbury - This existing Leisure Centre site contains two swimming pools and a health and fitness centre. The facility closed in July 2023 when the Sandwell Aquatics Centre opened for public use. The SAC provides equitable or better facilities in both quantity and quality , and is in a suitable location, in line with para 99 of the NPPF, and so Sport England has no objection to the loss of this site to sport.

SH43 (SA166) Land off Tanhouse Avenue, Great Barr - The site includes an area of disused playing field that has previously been delineated to provide a football pitch. The proposed allocation does not reference this, and does not identify the need to mitigate the loss of the playing field in line with para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Fields Policy, and so we object to this proposed allocation. To address this, either the proposed allocation should be deleted, or additional text be added to make it clear that the proposed allocation an only come forward subject to addressing the loss of former playing field in line with the above policies.

SM2 (SA199) Lion Farm, Oldbury - The site constitutes existing playing field for which para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Fields Policy apply. Sport England notes the allocation is for retention of 6 sports pitches with changing facilities and car parking (5 ha), with the remainder to be lost to a mix of residential, employment and open space uses. We note the reference that this allocation is strongly caveated by the ability to relocate 6 pitches to the southern part of the Borough, however this does not provide sufficient comfort that a proposal will come forward to provide replacement playing field that is equivalent or better quantity, equivalent or better quality, in a suitable location, and subject to equivalent or better accessibility and management arrangements to meet the relevant Exception criteria of our policy. The Council's own evidence base in the PPOSS 2022 identifies shortfalls of capacity for football in Oldbury and across the Borough, both now and in the future, with a recommendation to protect and enhance the quality of the existing pitches at Lion Farm. The site is well used for adult league football in the Warley Sunday League by several local teams whose demand would likely be displaced should the site be redeveloped. Sport England are aware that finding a suitable site(s) to replace 6 pitches will be extremely challenging for the Council in light of the findings and recommendations of the PPOSS, and so in the absence of detailed deliverable proposals that demonstrate how these pitches would be replaced in line with the relevant policies referred to above, Sport England is of the view that there is significant doubt that the caveat would be reasonably met. We consider this allocation to be in direct conflict with the Council's stated ambitions, vision and objectives of the Draft Plan, particularly those that seek to improve the health and well-being of Borough's residents. As such, Sport England strongly objects to the proposed allocation which should be removed from the plan.

SH3 (SA21) 88-90 Dudley Road West - The proposed allocation for housing would lead to the loss of an existing indoor cricket facility for which para 99 of the NPPF and draft policy SHW5 would apply. No reference is made to mitigating the loss of this existing sports facility or demonstrating it is surplus in accordance with these relevant policies. Sport England therefore objects to the proposed allocation, and would recommend that either the allocation be deleted from the plan, or be revised so as to ensure the sports facility is retained, or that additional text be added to make it clear that the proposed allocation can only come forward subject to addressing the loss of the facility in line with the above policies.

SH9 (SA28) The Phoenix Collegiate, Friar Park Road, Wednesbury - Notwithstanding that the site has an existing outline planning consent for residential development, this is subject to a section 106 agreement to secure mitigation for the loss of existing playing fields. The planning consent whilst still extant has not been implemented. It is important to recognise that the site contains existing playing fields, the loss of which would need to be mitigated in line with para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Field Policy and Guidance. As drafted the allocation does not address this and so Sport England raises an objection to the proposed allocation. To address this, the allocation wording should reference the need to mitigate the loss of playing field.

SH18 (SA55) Friar Park (STW/SMBC land), Wednesbury - Sport England recognises that the allocation does make reference to mitigating the loss of playing pitches in line with the PPOSS/Action Plan, but objects to this being subject to viability testing, since there is no relevant exception criteria for viability testing in para 99 of the NPPF, nor within draft policy SHW5, nor within Sport England's Playing Fields Policy and Guidance. To address, this we recommend that the reference to viability testing be removed.

SH34 (SA79) Brandhall Golf Course - The allocation references an existing planning application for redevelopment of the site, for which Sport England have objected. We recognise that there is no longer a need to retain the 18 hole municipal course, but take the view that mitigation should be secured to make qualitative improvements to the existing golf course facility at Warley Woods in line with the findings and recommendations of the PPOSS 2022. We understand that a planning condition has been included to secure this mitigation. To address this, we would recommend that an appropriate reference be added to the allocation regarding securing an appropriate the off-site contribution towards golf.

SH40 (SA94) Langley Swimming Centre, Vicarage Road, Oldbury - This existing Leisure Centre site contains two swimming pools and a health and fitness centre. The facility closed in July 2023 when the Sandwell Aquatics Centre opened for public use. The SAC provides equitable or better facilities in both quantity and quality , and is in a suitable location, in line with para 99 of the NPPF, and so Sport England has no objection to the loss of this site to sport.

SH43 (SA166) Land off Tanhouse Avenue, Great Barr - The site includes an area of disused playing field that has previously been delineated to provide a football pitch. The proposed allocation does not reference this, and does not identify the need to mitigate the loss of the playing field in line with para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Fields Policy, and so we object to this proposed allocation. To address this, either the proposed allocation should be deleted, or additional text be added to make it clear that the proposed allocation an only come forward subject to addressing the loss of former playing field in line with the above policies.

SM2 (SA199) Lion Farm, Oldbury - The site constitutes existing playing field for which para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Fields Policy apply. Sport England notes the allocation is for retention of 6 sports pitches with changing facilities and car parking (5 ha), with the remainder to be lost to a mix of residential, employment and open space uses. We note the reference that this allocation is strongly caveated by the ability to relocate 6 pitches to the southern part of the Borough, however this does not provide sufficient comfort that a proposal will come forward to provide replacement playing field that is equivalent or better quantity, equivalent or better quality, in a suitable location, and subject to equivalent or better accessibility and management arrangements to meet the relevant Exception criteria of our policy. The Council's own evidence base in the PPOSS 2022 identifies shortfalls of capacity for football in Oldbury and across the Borough, both now and in the future, with a recommendation to protect and enhance the quality of the existing pitches at Lion Farm. The site is well used for adult league football in the Warley Sunday League by several local teams whose demand would likely be displaced should the site be redeveloped. Sport England are aware that finding a suitable site(s) to replace 6 pitches will be extremely challenging for the Council in light of the findings and recommendations of the PPOSS, and so in the absence of detailed deliverable proposals that demonstrate how these pitches would be replaced in line with the relevant policies referred to above, Sport England is of the view that there is significant doubt that the caveat would be reasonably met. We consider this allocation to be in direct conflict with the Council's stated ambitions, vision and objectives of the Draft Plan, particularly those that seek to improve the health and well-being of Borough's residents. As such, Sport England strongly objects to the proposed allocation which should be removed from the plan.

SH3 (SA21) 88-90 Dudley Road West - The proposed allocation for housing would lead to the loss of an existing indoor cricket facility for which para 99 of the NPPF and draft policy SHW5 would apply. No reference is made to mitigating the loss of this existing sports facility or demonstrating it is surplus in accordance with these relevant policies. Sport England therefore objects to the proposed allocation, and would recommend that either the allocation be deleted from the plan, or be revised so as to ensure the sports facility is retained, or that additional text be added to make it clear that the proposed allocation can only come forward subject to addressing the loss of the facility in line with the above policies.

SH9 (SA28) The Phoenix Collegiate, Friar Park Road, Wednesbury - Notwithstanding that the site has an existing outline planning consent for residential development, this is subject to a section 106 agreement to secure mitigation for the loss of existing playing fields. The planning consent whilst still extant has not been implemented. It is important to recognise that the site contains existing playing fields, the loss of which would need to be mitigated in line with para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Field Policy and Guidance. As drafted the allocation does not address this and so Sport England raises an objection to the proposed allocation. To address this, the allocation wording should reference the need to mitigate the loss of playing field.

SH18 (SA55) Friar Park (STW/SMBC land), Wednesbury - Sport England recognises that the allocation does make reference to mitigating the loss of playing pitches in line with the PPOSS/Action Plan, but objects to this being subject to viability testing, since there is no relevant exception criteria for viability testing in para 99 of the NPPF, nor within draft policy SHW5, nor within Sport England's Playing Fields Policy and Guidance. To address, this we recommend that the reference to viability testing be removed.

SH34 (SA79) Brandhall Golf Course - The allocation references an existing planning application for redevelopment of the site, for which Sport England have objected. We recognise that there is no longer a need to retain the 18 hole municipal course, but take the view that mitigation should be secured to make qualitative improvements to the existing golf course facility at Warley Woods in line with the findings and recommendations of the PPOSS 2022. We understand that a planning condition has been included to secure this mitigation. To address this, we would recommend that an appropriate reference be added to the allocation regarding securing an appropriate the off-site contribution towards golf.

SH40 (SA94) Langley Swimming Centre, Vicarage Road, Oldbury - This existing Leisure Centre site contains two swimming pools and a health and fitness centre. The facility closed in July 2023 when the Sandwell Aquatics Centre opened for public use. The SAC provides equitable or better facilities in both quantity and quality , and is in a suitable location, in line with para 99 of the NPPF, and so Sport England has no objection to the loss of this site to sport.

SH43 (SA166) Land off Tanhouse Avenue, Great Barr - The site includes an area of disused playing field that has previously been delineated to provide a football pitch. The proposed allocation does not reference this, and does not identify the need to mitigate the loss of the playing field in line with para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Fields Policy, and so we object to this proposed allocation. To address this, either the proposed allocation should be deleted, or additional text be added to make it clear that the proposed allocation an only come forward subject to addressing the loss of former playing field in line with the above policies.

SM2 (SA199) Lion Farm, Oldbury - The site constitutes existing playing field for which para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Fields Policy apply. Sport England notes the allocation is for retention of 6 sports pitches with changing facilities and car parking (5 ha), with the remainder to be lost to a mix of residential, employment and open space uses. We note the reference that this allocation is strongly caveated by the ability to relocate 6 pitches to the southern part of the Borough, however this does not provide sufficient comfort that a proposal will come forward to provide replacement playing field that is equivalent or better quantity, equivalent or better quality, in a suitable location, and subject to equivalent or better accessibility and management arrangements to meet the relevant Exception criteria of our policy. The Council's own evidence base in the PPOSS 2022 identifies shortfalls of capacity for football in Oldbury and across the Borough, both now and in the future, with a recommendation to protect and enhance the quality of the existing pitches at Lion Farm. The site is well used for adult league football in the Warley Sunday League by several local teams whose demand would likely be displaced should the site be redeveloped. Sport England are aware that finding a suitable site(s) to replace 6 pitches will be extremely challenging for the Council in light of the findings and recommendations of the PPOSS, and so in the absence of detailed deliverable proposals that demonstrate how these pitches would be replaced in line with the relevant policies referred to above, Sport England is of the view that there is significant doubt that the caveat would be reasonably met. We consider this allocation to be in direct conflict with the Council's stated ambitions, vision and objectives of the Draft Plan, particularly those that seek to improve the health and well-being of Borough's residents. As such, Sport England strongly objects to the proposed allocation which should be removed from the plan.

SH3 (SA21) 88-90 Dudley Road West - The proposed allocation for housing would lead to the loss of an existing indoor cricket facility for which para 99 of the NPPF and draft policy SHW5 would apply. No reference is made to mitigating the loss of this existing sports facility or demonstrating it is surplus in accordance with these relevant policies. Sport England therefore objects to the proposed allocation, and would recommend that either the allocation be deleted from the plan, or be revised so as to ensure the sports facility is retained, or that additional text be added to make it clear that the proposed allocation can only come forward subject to addressing the loss of the facility in line with the above policies.

SH9 (SA28) The Phoenix Collegiate, Friar Park Road, Wednesbury - Notwithstanding that the site has an existing outline planning consent for residential development, this is subject to a section 106 agreement to secure mitigation for the loss of existing playing fields. The planning consent whilst still extant has not been implemented. It is important to recognise that the site contains existing playing fields, the loss of which would need to be mitigated in line with para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Field Policy and Guidance. As drafted the allocation does not address this and so Sport England raises an objection to the proposed allocation. To address this, the allocation wording should reference the need to mitigate the loss of playing field.

SH18 (SA55) Friar Park (STW/SMBC land), Wednesbury - Sport England recognises that the allocation does make reference to mitigating the loss of playing pitches in line with the PPOSS/Action Plan, but objects to this being subject to viability testing, since there is no relevant exception criteria for viability testing in para 99 of the NPPF, nor within draft policy SHW5, nor within Sport England's Playing Fields Policy and Guidance. To address, this we recommend that the reference to viability testing be removed.

SH34 (SA79) Brandhall Golf Course - The allocation references an existing planning application for redevelopment of the site, for which Sport England have objected. We recognise that there is no longer a need to retain the 18 hole municipal course, but take the view that mitigation should be secured to make qualitative improvements to the existing golf course facility at Warley Woods in line with the findings and recommendations of the PPOSS 2022. We understand that a planning condition has been included to secure this mitigation. To address this, we would recommend that an appropriate reference be added to the allocation regarding securing an appropriate the off-site contribution towards golf.

SH40 (SA94) Langley Swimming Centre, Vicarage Road, Oldbury - This existing Leisure Centre site contains two swimming pools and a health and fitness centre. The facility closed in July 2023 when the Sandwell Aquatics Centre opened for public use. The SAC provides equitable or better facilities in both quantity and quality , and is in a suitable location, in line with para 99 of the NPPF, and so Sport England has no objection to the loss of this site to sport.

SH43 (SA166) Land off Tanhouse Avenue, Great Barr - The site includes an area of disused playing field that has previously been delineated to provide a football pitch. The proposed allocation does not reference this, and does not identify the need to mitigate the loss of the playing field in line with para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Fields Policy, and so we object to this proposed allocation. To address this, either the proposed allocation should be deleted, or additional text be added to make it clear that the proposed allocation an only come forward subject to addressing the loss of former playing field in line with the above policies.

SM2 (SA199) Lion Farm, Oldbury - The site constitutes existing playing field for which para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Fields Policy apply. Sport England notes the allocation is for retention of 6 sports pitches with changing facilities and car parking (5 ha), with the remainder to be lost to a mix of residential, employment and open space uses. We note the reference that this allocation is strongly caveated by the ability to relocate 6 pitches to the southern part of the Borough, however this does not provide sufficient comfort that a proposal will come forward to provide replacement playing field that is equivalent or better quantity, equivalent or better quality, in a suitable location, and subject to equivalent or better accessibility and management arrangements to meet the relevant Exception criteria of our policy. The Council's own evidence base in the PPOSS 2022 identifies shortfalls of capacity for football in Oldbury and across the Borough, both now and in the future, with a recommendation to protect and enhance the quality of the existing pitches at Lion Farm. The site is well used for adult league football in the Warley Sunday League by several local teams whose demand would likely be displaced should the site be redeveloped. Sport England are aware that finding a suitable site(s) to replace 6 pitches will be extremely challenging for the Council in light of the findings and recommendations of the PPOSS, and so in the absence of detailed deliverable proposals that demonstrate how these pitches would be replaced in line with the relevant policies referred to above, Sport England is of the view that there is significant doubt that the caveat would be reasonably met. We consider this allocation to be in direct conflict with the Council's stated ambitions, vision and objectives of the Draft Plan, particularly those that seek to improve the health and well-being of Borough's residents. As such, Sport England strongly objects to the proposed allocation which should be removed from the plan.

SH3 (SA21) 88-90 Dudley Road West - The proposed allocation for housing would lead to the loss of an existing indoor cricket facility for which para 99 of the NPPF and draft policy SHW5 would apply. No reference is made to mitigating the loss of this existing sports facility or demonstrating it is surplus in accordance with these relevant policies. Sport England therefore objects to the proposed allocation, and would recommend that either the allocation be deleted from the plan, or be revised so as to ensure the sports facility is retained, or that additional text be added to make it clear that the proposed allocation can only come forward subject to addressing the loss of the facility in line with the above policies.

SH9 (SA28) The Phoenix Collegiate, Friar Park Road, Wednesbury - Notwithstanding that the site has an existing outline planning consent for residential development, this is subject to a section 106 agreement to secure mitigation for the loss of existing playing fields. The planning consent whilst still extant has not been implemented. It is important to recognise that the site contains existing playing fields, the loss of which would need to be mitigated in line with para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Field Policy and Guidance. As drafted the allocation does not address this and so Sport England raises an objection to the proposed allocation. To address this, the allocation wording should reference the need to mitigate the loss of playing field.

SH18 (SA55) Friar Park (STW/SMBC land), Wednesbury - Sport England recognises that the allocation does make reference to mitigating the loss of playing pitches in line with the PPOSS/Action Plan, but objects to this being subject to viability testing, since there is no relevant exception criteria for viability testing in para 99 of the NPPF, nor within draft policy SHW5, nor within Sport England's Playing Fields Policy and Guidance. To address, this we recommend that the reference to viability testing be removed.

SH34 (SA79) Brandhall Golf Course - The allocation references an existing planning application for redevelopment of the site, for which Sport England have objected. We recognise that there is no longer a need to retain the 18 hole municipal course, but take the view that mitigation should be secured to make qualitative improvements to the existing golf course facility at Warley Woods in line with the findings and recommendations of the PPOSS 2022. We understand that a planning condition has been included to secure this mitigation. To address this, we would recommend that an appropriate reference be added to the allocation regarding securing an appropriate the off-site contribution towards golf.

SH40 (SA94) Langley Swimming Centre, Vicarage Road, Oldbury - This existing Leisure Centre site contains two swimming pools and a health and fitness centre. The facility closed in July 2023 when the Sandwell Aquatics Centre opened for public use. The SAC provides equitable or better facilities in both quantity and quality , and is in a suitable location, in line with para 99 of the NPPF, and so Sport England has no objection to the loss of this site to sport.

SH43 (SA166) Land off Tanhouse Avenue, Great Barr - The site includes an area of disused playing field that has previously been delineated to provide a football pitch. The proposed allocation does not reference this, and does not identify the need to mitigate the loss of the playing field in line with para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Fields Policy, and so we object to this proposed allocation. To address this, either the proposed allocation should be deleted, or additional text be added to make it clear that the proposed allocation an only come forward subject to addressing the loss of former playing field in line with the above policies.

SM2 (SA199) Lion Farm, Oldbury - The site constitutes existing playing field for which para 99 of the NPPF, draft policy SHW5 and Sport England's Playing Fields Policy apply. Sport England notes the allocation is for retention of 6 sports pitches with changing facilities and car parking (5 ha), with the remainder to be lost to a mix of residential, employment and open space uses. We note the reference that this allocation is strongly caveated by the ability to relocate 6 pitches to the southern part of the Borough, however this does not provide sufficient comfort that a proposal will come forward to provide replacement playing field that is equivalent or better quantity, equivalent or better quality, in a suitable location, and subject to equivalent or better accessibility and management arrangements to meet the relevant Exception criteria of our policy. The Council's own evidence base in the PPOSS 2022 identifies shortfalls of capacity for football in Oldbury and across the Borough, both now and in the future, with a recommendation to protect and enhance the quality of the existing pitches at Lion Farm. The site is well used for adult league football in the Warley Sunday League by several local teams whose demand would likely be displaced should the site be redeveloped. Sport England are aware that finding a suitable site(s) to replace 6 pitches will be extremely challenging for the Council in light of the findings and recommendations of the PPOSS, and so in the absence of detailed deliverable proposals that demonstrate how these pitches would be replaced in line with the relevant policies referred to above, Sport England is of the view that there is significant doubt that the caveat would be reasonably met. We consider this allocation to be in direct conflict with the Council's stated ambitions, vision and objectives of the Draft Plan, particularly those that seek to improve the health and well-being of Borough's residents. As such, Sport England strongly objects to the proposed allocation which should be removed from the plan.

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 supports the reference to the agent of change principle in part 6 of the policy and associated text in paragraph 14.19 in how this relates to ensuring unreasonable restrictions are not placed on the functioning of existing businesses and community facilities, which includes sports facilities. This is entirely consistent with the guidance in para 187 of the NPPF.

Sport England supports the approach in this policy to achieving good place making, and welcomes the reference in para 15.18 to Sport England's Active Design guidance, within which we draw out how Sport England's 10 Active Design principles align with those within the National Design Guide. Where possible we would support embedding a hyperlink to the guidance within this paragraph so that this is readily accessible to the reader.

https://www.sportengland.org/guidance-and-support/facilities-and-planning/design-and-cost-guidance/active-design