LETTER: Proper protection for our facilities

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In last week’s WSCT, Dr Roger Smith (CPRE) expressed his view that adoption of HDPF policies would significantly weaken protection for the ‘natural environment’; not only making it worse than the replaced HDC Core Strategy but also less than that stipulated under the NPPF. He described the council’s intent as ‘beyond appalling’. I agree with him and I also question whether this approach is deliberate strategy or just incompetence at HDC in drafting planning policy?

Well, HDC appears to be attempting exactly the same approach regarding the stringent protection for ‘open space, sports and recreation facilities’ that has featured in national planning policy for many, many years, originally under PPG17 and now under the NPPF paras 73 and 74.

In essence these national policies state that provision of such facilities should be determined by robust assessment of sporting need and they also disallow redevelopment of such sites for ‘non-sports’ usage unless surplus to sporting requirement.

The HDC Core Strategy policies (which will be replaced by the HDPF) specifically invoked this national policy protection, but the HDPF (Policy 43) doesn’t and so will diminish the important protection of such facilities. Why would HDC want to do that?

Do you recall autumn 2011 when HDC’s Cabinet infamously and unanimously voted to recommend bulldozing the ‘surplus to requirement’ BBH Leisure Centre in favour of retail units?

I certainly do and so I was very concerned at this ‘policy change by stealth’ and hence vigorously challenged this aspect as part of the hearings process.

Unsurprisingly HDC planners were adamant that all was OK but fortunately the Planning Inspector eventually ruled against their proposed wording and ordered a modification.

So far so good you may think, but the HDC planners have now put forward a modification (MM28) that is inadequate as it still doesn’t offer the very specific protection of NPPF, mainly para 74.

For example, the amended policy would still allow needed sports facilities to be removed if ‘unfeasible’, i.e. they don’t make enough money etc. Or it would allow part of a facility to be turned over to other uses (retail, shops etc) leaving a smaller, inadequate sports facility.

The policy would even allow (for example) a leisure centre to be redeveloped as a pub, since pubs are classified (in the HDPF) as community facilities of worth equivalent to sports facilities!

So, if you want to stop HDC degrading this important protection for sports facilities you do have an opportunity as MM28 is part of the limited scope of the current HDPF modifications consultation. If there are enough concerns expressed, then maybe the Inspector will again rule that HDC have got this policy wrong and order a further change. You have till 5:20pm on Tuesday 5th May to comment!

So is this policy change deliberate strategy or incompetence? Regardless of which, let’s stop it and demand that the HDPF maintains proper protection for our open space, sports and recreation facilities.

Any policy giving less protection than current national guidelines and the replaced HDC Core Strategy is surely unacceptable and definitely ‘beyond appalling’.


Cox Green, Rudgwick