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Representation by Sport England (Sport England)

Date submitted
21 February 2023
Submitted by
Members of the public/businesses

Sport England is the non-departmental public body responsible for delivering the Government’s community sporting and physical activity objectives. Sport England is also a statutory consultee on planning applications affecting playing fields. Sport England made comments on the original, supplementary, design refinements and community impacts consultations on the Lower Thames Crossing between 2018-2021 before the DCO application was accepted. Positive proposals have been made in the DCO for addressing many of the issues raised in our pre-application consultation responses which are welcomed such as the proposals for restoring sports facility sites that are required for temporary construction works and utility related works. However, Sport England would like to make a representation on the DCO to cover the following points: • The scope of the proposed Requirements (in the Schedule of Requirements) in relation to the replacement of Gravesend Golf Centre needs to provide more detail on the information that would need to be submitted and approved on replacement golf facility provision. This is necessary in order to meet the criteria for replacement provision set out in paragraph 5.166 of the NSPNN relating to replacement provision being equivalent or better in terms of quantity and quality; • The need for clarification on the scope of the impact and the proposed mitigation for the loss of the Gravesend Golf Centre and potentially the Cascades Leisure Centre recreation ground as there would appear to be inconsistencies between the submitted documents. Schedule 1 part 2 of the DCO requires the authorised development to be designed in detail and carried out in accordance with the design principles document and the preliminary scheme design shown on the engineering drawings and sections. The Planning Statement (Appendix G: Private Recreational Facilities) identifies the loss of a 9 hole par 3 course at Gravesend Golf Centre and its replacement on part of the existing Southern Valley Golf Course. However, the Design Principles document Table 5.3, S3.17 refers only to the replacement of a recreation ground for Gravesend Borough Council adjacent to Cascades Leisure Centre to be developed in co-ordination with the Council. There would not appear to be any other reference to the loss of part of this recreation ground in any of the documents supporting the DCO and there is no reference in the Design Principles document to the replacement of the private Gravesend Golf Centre 9 hole course. • The need for an additional ‘Requirement’ (in the Schedule of Requirements) relating to the drainage impact on playing fields in close proximity to the area covered by the DCO. The impact of the development on drainage of playing fields adjoining the construction area has been acknowledge in the Environmental Statement (Chapter 13) This would involve a baseline assessment of the ground conditions of identified playing fields being undertaken in advance of any works commencing and for a similar assessment to be undertaken following the completion of the works to assess whether the drainage capacity of the playing fields has been adversely affected directly by the project. Provision would need to be made in the ‘Requirement’ for any adverse impact attributed to the project to be satisfactorily mitigated within an agreed timescale; • The need to assess the impact of the project on a private playing field site that was not covered in Planning Statement Appendix G that would be directly affected by the proposals. This is the Orsett Park Royals Football Club site to the north west of the Orsett Cock A13 junction. This site was assessed as part of the previous ‘Community Impacts Consultation’ in 2021 but has not been considered as part of the DCO. It is considered that the impact could be resolved if access could be maintained to the majority of the playing field during the works and if the area to the south of the playing field that would be affected was restored in accordance with the Project’s provision of reinstatement. Sport England would be happy to discuss the above points with a view to reaching mutually agreeable solutions as the examination progresses.