Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

Support is offered for the Vision as it supports healthy lifestyles by maximising the opportunities provided through well connected green networks. The vision would align with Sport England’s Uniting the Movement Strategy and Government policy in paragraph 96 of the NPPF. The content of paragraph 2.2 of the supporting text is particularly supported as it recognises the important role that planning and design play in creating opportunities for healthy and active lifestyles.

Policy ST1 is supported for the following reasons:

• It expects all developments to be designed to provide opportunities for healthy lifestyles.
• It supports the creation of well designed, safe and accessible places.
• It promotes active and sustainable environments
• It requires Health Impact Assessments for all major developments
The policy would accord with Sport England’s Uniting the Movement Strategy and Active Design Guidance and would also be consistent with Government planning policy especially in paragraphs 96 and 129 of the NPPF.

The policy is welcomed as it requires on-site or off-site infrastructure to be provided to meet the needs generated by new development. As set out in paragraph 3.65 of the reasoned justification such infrastructure would include sport and leisure provision. This approach is necessary to support the local plan’s strategic priorities, is supported by the Council’s current evidence base for sports facilities and is consistent with current Government policy in paragraphs 96 and 103 of the NPPF.

Support is offered for Policy ST8 as it includes principles that would support providing opportunities for healthy and active lifestyles especially principles b, h, i, j and l. These principles would align with Sport England’s Active Design principles which are intended to support active lifestyles through design. However, the following suggestions are made for enhancing the policy:

• Principle i) could be extended to support the co-location of community facilities in new developments. The provision of facilities such as schools, shops, workplaces and strategic open spaces in close proximity to each other reduces the number of trips people to have to make and thereby encourages active travel. The principle could also be enhanced by reference being made to ‘walkable’ neighbourhoods
• Principles j) or l) could be extended to support infrastructure in the public realm that encourages physical activity such as seating, cycle parking and appropriate lighting

The requirement in criterion (f) for SuDS to be multi-functional and provide aesthetic and amenity value and safe public access is welcomed. SuDS can provide a recreational resource in new developments and if appropriately designed can encourage people to visit them as a recreational destination by active travel modes thereby encouraging physical activity in close proximity to where people live and work.

It is requested that the policy is amended to provide guidance on the agent of change principle for pollution sensitive uses. Intensively used community sports facilities such as artificial grass pitches, multi-use games areas, tennis/netball courts etc can generate impacts such as noise and lighting. Where sensitive developments such as residential are located in close proximity to such existing uses this can potentially compromise the operation of such facilities due to complaints made by residents/businesses if appropriate mitigation is not included in such development at the outset. It is therefore requested that the policy is amended to include advice on this matter to provide consistency with paragraph 200 of the NPPF.

Policy GN1 is broadly supported for the following reasons:
• It expects open spaces in residential developments to be multi-functional to create healthier neighbourhoods.
• It expects opens spaces in developments to be designed to be accessible and inclusive.
The policy would broadly accord with Sport England’s Active Design Guidance and would also be consistent with Government planning policy especially in paragraphs 96 and 129 of the NPPF. However, the following suggestion is made for enhancing the policy:
• Explicit reference could be made to designing open spaces so that they support physical activity e.g. through the provision of supporting infrastructure where appropriate such as seating, toilets, cycle parking etc. Sport England’s Active Design guidance especially principles 5 and 7 provide further advice on how this can be achieved in practice. Such a reference would support embedding the Local Plan’s vision for supporting healthy lifestyles into open space policies.

It is requested that clarity is provided in the reasoned justification that proposals affecting playing fields and other outdoor sports facilities will be assessed against Policy CS4: Sports Provision as this policy is specifically intended for assessing development proposals affecting outdoor sports facilities. The scope of open space is often interpreted to include outdoor sports facilities especially playing fields. As the criteria in policies GN6 and CS4 are different there is a risk of potential confusion about which policy should be applied to outdoor sports facilities and developers may exploit this by making the case that GN6 applies if this offers them more potential for compliance with the Local Plan than CS4.

It is requested that clarity is provided in the reasoned justification that proposals affecting sports facilities will be assessed against Policy CS4: Sports Provision as this policy is specifically intended for assessing development proposals affecting sports facilities. The scope of community facilities is often interpreted to include sports facilities especially indoor sports facilities such as leisure centres and swimming pools. As the criteria in policies CS1 and CS4 are different there is a risk of potential confusion about which policy should be applied to sports facilities and developers may exploit this by making the case that CS1 applies if this offers them more potential for compliance with the Local Plan than CS4. Furthermore, Policy CS4 has prepared to be consistent with paragraph 104 of the NPPF which specifically relates to sports facilities. Policy CS1 covers a broader range of community facilities and therefore the criteria are not the same as those in paragraph 104 of the NPPF

The indoor and outdoor sports facilities on education sites make a significant contribution to meeting the community’s indoor and outdoor sports facilities in Colchester and this has been evidenced by the Council’s Playing Pitch Strategy and Indoor & Built Facilities Strategy which forms the Local Plan’s sports facility evidence base. Most schools in Colchester have formal or informal arrangements to allow community access to their facilities outside of school hours. These strategies recommend the protection of sports facilities on education sites regardless of whether the educational use is operational. In scenarios where educational sites are demonstrated to be redundant from an educational needs perspective this does not mean that their sports facilities are also redundant or surplus to requirements in terms of meeting community needs. The policy in its current form would potentially allow school playing fields and other sports facilities that are used extensively by the community to be considered surplus to requirements if there are existing alternative facilities and/or capital receipts are invested in improving or expanding other education facilities. The criteria in this policy would not be consistent with Government policy relating to sports facilities including playing fields as they would not accord with paragraph 104 of the NPPF which applies to all sports facilities including those on education sites (and Sport England’s Playing Fields Policy which is applied by Sport England as a statutory consultee). To address this, it is suggested that Policy CS3 is qualified to confirm that proposals for alternative uses affecting sports facilities on education sites will also need to meet the requirements of Policy CS4. This would help avoid potential misinterpretations that if a proposal involving the loss of sports facilities on education sites met Policy CS3 it would not need to also meet Policy CS4. If the policy is maintained in its current form Sport England would have to object at the Regulation 19 stage.

In relation to new school and education facilities it is requested that the policy is amended to expect new facilities to be designed to support community use outside of school hours and that the completion of community use agreement will be expected to secure community access over a long term period. As well as according with paragraph 98 (a) of the NPPF this would accord with the recommendations of the Council’s evidence base in the Playing Pitch Strategy and the Indoor & Built Facilities Strategy. It would also contribute to delivering the Local Plan’s vision in relation to providing opportunities for healthy lifestyles and reducing health inequalities especially as schools are usually located centrally within the communities where residents live.