Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Object

Representation ID: 940

Received: 29/01/2026

Respondent: Sport England (Statutory / General Consultation Body)

Comment to update / strengthen

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 note the Council’s completed Playing Pitch Strategy in 2022 which covers pitch sports, tennis and bowls. There is no current in date assessment for swimming pools, sports halls, golf courses, athletics tracks, cycling, equestrian, motor sports etc which the Council may consider as a future phase of sporting assessment to provide evidence for the development plan.

The Playing Pitch Strategy (PPS) for ‘in date’ the data in studies should not be more than 3 years old (from the date of the data and not the adoption date). A delivery group currently meets to discuss changes in the supply and demand data but the group needs to acknowledge the need for a full update of the PPS.

The Built Sport Facility Strategy for ‘in date’ the data in studies should not be more than 5 years old (from the date of the data and not the adoption date). The study for the Council was completed in 2014 so 12 years old.

Action – Torbay to work on updating the Local Plan evidence base for sport to ensure soundness of the Local Plan (as advocated in the Plan).

Limitations on the use of Standards – Strategic Policy SC2: Sport, leisure and recreation for healthy living

Standards are sometimes used to help quantify the need that may be generated from a development. However, as set out below there are some risks and weaknesses with their use that should be highlighted:

i. The NPPF does not advocate the use of local standards for assessing the needs or providing for sporting provision (unlike PPG17 (2002) which it replaced). It terms of
planning for sport and recreation it advises that specific evidence of the need for provision should be provided along with clarity of what provision is required NPPF paragraph 103 and develop more specific evidence including quality and accessibility.

ii. The existence of a local standard in a Local Plan, or other development plan document, does not necessarily in itself justify the requirement to seek provision for a specific
facility type from an individual development. It would need to be underpinned by a robust assessment of need and developed further to provide a specific local requirement (e.g. an identified project or contribution to an identified project) informed by appropriate feasibility studies, costings etc.

iii. If the underlying evidence base, and how the standard has been developed, is not robust and up to date then it may be difficult to justify their use.

iv. Standards propose a certain amount of new provision for a given population. This level of new provision may not be necessary and may not relate to identified needs and actions as set out in a supporting evidence base document. For example, improving the quality or accessibility of existing provision to increase its capacity may be a more appropriate way to meet the need generated by a development.

v. Standards do not provide details of the needs that may be generated for the actual use of a facility. Standards therefore have limitations when seeking to improve existing provision to increase its capacity.

vi. Standards can be too generic with a single standard covering a number of facility or pitch types (e.g. x hectares for outdoor sport as opposed to a local assessment that may identify a shortfall of cricket and youth football pitches but adequate provision of adult football pitches). Such standards do not reflect the range of needs for different facility types that fall under a generic heading, or provide any certainty as to what specific needs will be generated from a development and therefore what provision is necessary;

vii. Applying a standard without robust evidence that existing provision, within a reasonable catchment of the individual development and in its current condition, is unable to meet the additional need will fail to demonstrate that the provision sought is necessary.

viii. The standard for playing pitch here specified is for the quantum only. Not the quality or accessibility. This weakens its use in implementation.

Action – The Council to reconsider the use of standards in the provision of sport including playing pitches.

Support

Representation ID: 942

Received: 29/01/2026

Respondent: Sport England (Statutory / General Consultation Body)

Planning Obligations/Community Infrastructure Levy (CIL) to Sport – Policy SC5: Community facilities, infrastructure provision and developer contributions

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 Torbay 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.

The evidence base (as mentioned in comment 1 above) should inform the Infrastructure Delivery Plan (IDP) and / or CIL / use of planning obligations. Sport England supports policy SC5 if this includes sport and recreation land and buildings including playing fields.

Action – The Council to confirm and clarify.

Support

Representation ID: 943

Received: 29/01/2026

Respondent: Sport England (Statutory / General Consultation Body)

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 playing fields used by schools (public and private) in Torbay.

Sport England considers proposals affecting playing fields in light of the National Planning Policy Framework (NPPF) (in particular Para. 104) 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:
www.sportengland.org/playingfieldspolicy

We support the protection part of the Strategic Policy SC2: Sport, leisure and recreation for healthy living.

Above in comment 2, Sport England questions the limitations of standards as highlighted in Strategic Policy SC2: Sport, leisure and recreation for healthy living.

Support

Representation ID: 944

Received: 29/01/2026

Respondent: Sport England (Statutory / General Consultation Body)

Active Design – Strategic Policy SC1: Public health and wellbeing & Chapter 5 Thriving Communities – Wellbeing, safety and belonging and Policy DE2: Building for a Healthy Life

Active Design will help improve health and well-being as well as addressing climate change and promoting active travel – more walking and cycling. Active design is more than active travel. This has considerable understanding with the Plan in particular:

Strategic Policy SC1: Public health and wellbeing

Chapter 5 Thriving Communities – Wellbeing, safety and belonging

Policy DE2: Building for a Healthy Life

Para 5.4 “Health, well-being and the built environment are inextricably linked. The implications of the proposals upon the health and the well-being of the affected communities must be considered at plan making and planning application stages. Health and well-being is enhanced by attractive, inspiring environments and contact with nature.” This is Active Design.

Para 11.5 “Design should seek to promote healthy and active lifestyles. Guidance and a developer checklist on “Active Design. Whilst we support this reference, Active
Design is more than a checklist. Sport England, working with Active Travel England and the Office for Health Improvement and Disparities, has produced the 3rd version of ‘Active Design’ (May 2023), a guide to planning new developments that create the right environment to help people get more active, more often in the interests of health and wellbeing. The guidance sets out ten key principles for ensuring new developments incorporate opportunities for people to take part in sport and physical activity. The Active Design principles are aimed at contributing towards the Government’s desire for the
planning system to promote healthy communities through good urban design. Sport England would commend the use of the guidance in the master planning process for new residential developments.

Support

Representation ID: 1013

Received: 29/01/2026

Respondent: Sport England (Statutory / General Consultation Body)

Active Design – Strategic Policy SC1: Public health and wellbeing & Chapter 5 Thriving Communities – Wellbeing, safety and belonging and Policy DE2: Building for a Healthy Life

Active Design will help improve health and well-being as well as addressing climate change and promoting active travel – more walking and cycling. Active design is more than active travel. This has considerable understanding with the Plan in particular:

Strategic Policy SC1: Public health and wellbeing

Chapter 5 Thriving Communities – Wellbeing, safety and belonging

Policy DE2: Building for a Healthy Life

Para 5.4 “Health, well-being and the built environment are inextricably linked. The implications of the proposals upon the health and the well-being of the affected communities must be considered at plan making and planning application stages. Health and well-being is enhanced by attractive, inspiring environments and contact with nature.” This is Active Design.

Para 11.5 “Design should seek to promote healthy and active lifestyles. Guidance and a developer checklist on “Active Design. Whilst we support this reference, Active
Design is more than a checklist. Sport England, working with Active Travel England and the Office for Health Improvement and Disparities, has produced the 3rd version of ‘Active Design’ (May 2023), a guide to planning new developments that create the right environment to help people get more active, more often in the interests of health and wellbeing. The guidance sets out ten key principles for ensuring new developments incorporate opportunities for people to take part in sport and physical activity. The Active Design principles are aimed at contributing towards the Government’s desire for the
planning system to promote healthy communities through good urban design. Sport England would commend the use of the guidance in the master planning process for new residential developments.