Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by Business in Sport and Leisure Limited (BISL) (PPG 08)

  1.1  Business In Sport and Leisure (BISL) is an umbrella organisation which represents over 100 private sector companies in the sport and leisure industry. Its members include most of the major operators of commercial sport and leisure in the UK and many consultants who specialise in this field. Members of BISL who are listed on the London Stock Exchange have a combined market capitalisation in excess of £40 billion. Activities range from operators of health and fitness clubs to those involved in sport tourism, running local authority leisure facilities under PPP arrangements and professional rugby clubs plus a wide range of consultants in these fields. A full list can be found on our website (

  1.2  BISL has working groups on both Property/Planning and Sport comprising experts and representatives of senior management from our member companies in those fields, and BISL has long had an interest in land-use planning issues. We have published and revised our booklet "A Guide to Site Criteria for Commercial Leisure" which looks at 19 different types of facilities, including an indoor tennis, sport and leisure club; private members health and fitness clubs; hotels with leisure facilities; multi-purpose small stadia; and stadium complexes. We also responded to the Government's recent consultation on the revision of PPG 17.

  1.3  BISL would welcome the opportunity to give oral evidence to the Committee on behalf of the private sector sport and leisure industry on the specific areas listed in the summary at the end of this submission.


  2.1  Sport is a cornerstone of the Government's policies towards education, health and law and order. Many benefits are spelt out in BISL's submission on the draft PPG 17, but without facilities many sports cannot take place. In putting forward a revision to PPG 17, DTLR should be reflecting central Government policy and ensuring that local planning authorities understand the vital importance of planning for sport. Nothing in the revision presented thus far does anything to encourage any person or body to think that sport is important.

  2.2  BISL believes that it is absolutely vital that PPG 17 sets the national context for sport. It should encourage local authorities to identify sites and policies which ensure that facilities for sport are refurbished and built afresh. Sport England estimates that £3.2 billion is required to update sports facilities in England to bring them up to the standards required by a discerning public. This will inevitably mean use of the private sector to provide investment (see case studies below) through schemes such as Best Value, Public Private Partnerships or via planning gain. The draft PPG must take account of the modern mechanisms by which facilities are provided, and provide guidance on how the planning system can assist in the securing of investment in these facilities. Currently, it appears intent on making things more difficult for the sports operator.

  2.3  Sport has seldom been at the top of the agenda for local authority planners and this revision does nothing to encourage a change in this culture for land-use planning. We would like to see local authorities have a statutory responsibility to plan for and provide or allow others to provide sporting facilities of a quality and type to suit their catchment areas. This should include the need for "additional" sports and leisure facilities. The draft PPG refers to a need for such provision, but does not specifically state a need for the allocation of sites in Development Plans.

  2.4  Turning to the specific terms of reference for this inquiry, we would like to comment as follows:


  3.1  The Committee has expressed a particular interest in the contribution of the draft PPG 17 to strategic planning for sport. BISL would like to discuss the following issues with the Committee:

  3.2  Strategic planning for sport is vital at a regional and local level, in Regional Development Plans, Local Development Plans and Unitary Development Plans. The revised PPG 17 does not do enough to encourage the planners responsible for these plans, or to see planning for sport as a priority. The PPG should provide guidance on how Local Planning Authorities should take a strategic approach to sports provision within their area. Reference should be made to the Sport England publication "Planning Across Boundaries". It is now widely accepted that participation in sport can contribute to the health of the nation, to improved standards in education and to an enhanced lifestyle for people in deprived communities and those who are socially excluded. The provision of good, modern, well-designed and well-located sports facilities is vital to the local community. The revised PPG should go much further in supporting the policies and programmes promoted by the Department of Health, Home Office and by DCMS. There is a real need for joining up these key threads within the revised PPG 17.

  3.3  Annex 1 contains three case studies demonstrating ways in which sporting facilities are provided by the commercial sector. We believe that these are in tune with the aims of the Urban White Paper, both in terms of attracting investment and improving sports provision, with the associated benefits that these bring to communities. We would like to see the draft PPG 17 amended in order to encourage more schemes of this nature.


  4.1  In this section, we would particularly like to comment on the location of sports facilities and the underlying economic factors which influence the provision of sporting facilities.

The Location of Sports Facilities

  4.2  The draft PPG 17 relies heavily on Government policies on planning as set out in PPG 6 (Town Centres and Retail) and PPG 13 (Transport). Both sets of guidance rely rigidly on the precept that new facilities should be built exclusively in town centres and be accessible primarily by public transport. Sport is, however, different for the following reasons:

  4.3  Few sites available in town centres are large enough for sport. Even if they are suitable, they are almost always too valuable for use by a non-profit making activity, such as amateur sports clubs.

  4.4  PPG 6 in particular encourages people to live and work in town centres. Many people in the UK do live in town centres, but equally many people live outside the town centre in residential suburbs or rural areas. Sports facilities must cater for everyone and participation in sport must be encouraged from a young age if children are going to adopt healthy lifestyles for the future. Sports facilities should be near to home, preferably available on foot or be adjacent to schools. The New Opportunities Fund has £750 million available over the next three years to fund new and refurbish existing sports facilities and most of the funding will be available for capital grants. The new guidance makes no mention of this significant capital allocation or any comment on the significant new funding which the National Lottery has introduced for sport over the past six years. The availability of this funding has key implications for planning policy for sport and the draft PPG should give clear guidance. Furthermore, sport operators will find it difficult or impossible to afford the prices of sites in town centres, particularly those identified for A3 or A1 use.

  4.5  There seems to be little mention of sports facilities in rural areas where public transport is often unavailable. In rural areas it may make more sense to place sports facilities on the edge of town centres so that users from the surrounding villages do not have to take their cars into the town centre. This can often increase their journey time ten fold. This was recognised in recent DETR research on "Planning for Leisure and Tourism" (March 2001).

  4.6  There is a need for a greater understanding of different types of sports facilities. Health clubs are suitable for many different locations to cater for office workers, and with easy access for use from home. Indoor tennis facilities need large sites, are most unlikely to be situated in town centres and may well be suited for sites adjacent to open space. Multi sports pitches are often only viable if they are flood-lit. They have to be located in areas where they will not cause undue nuisance to local residents.

  4.7  The Urban White Paper and Lord Foster's Urban Task Force Report looks at establishing sustainable communities where facilities are available to "neighbourhoods". This means that sports facilities should be part of planning in suburbs and in new towns. There is little evidence that this approach is appreciated in the draft PPG 17.

  To summarise the section, the main points to consider are:

    —  The location of various types of sporting facilities will depend on the nature of the facility; size/noise/floodlighting/attendees, rather than an automatic assumption that all new developments should be located in town centres.

    —  Consideration should be given to the visitors to sporting facilities when deciding on the location of new sports facilities. It will often be more appropriate for new developments to be located in residential areas to reduce the need for people to travel into town centres.

    —  Rather than looking at the sequential approach to site selection, travel patterns should have more priority, whereby consideration is given to sites which are most accessible by a variety of modes of transport for the population.

Economic Factors

  4.8  The draft PPG makes it clear that decisions on the location of sports facilities should be taken on planning grounds alone and that economic factors have little bearing on the decision making process. This ignores the fact that sport is rarely an economic activity and if the private sector is to be encouraged to invest in sport, then the sites available have to be sustainable. Sport and leisure facilities can be both commercial and non-commercial facilities. Each type of facility has its advantages for the community and needs recognition.

  4.9  Most sports facilities provided by the private sector have to include changing rooms, administrative accommodation and social facilities. Sport is no longer just about participating and moving on. Sports centres are seen as places for social activity, somewhere to meet and relax. The lifestyle and essential ingredient of quality in new and refurbished sports facilities which will encourage people to use them must be allowed for and encouraged by planning authorities. There seems little mention of this in the revised draft.

  4.10  It should be noted that one of the Key Measures within the Urban White Paper is the need for incentives to boost private investment, as is the need to promote culture, leisure and sporting activity. New Sports facilities can provide a focus for regeneration; bringing both people and investment into previously run down areas.


  5.1  BISL welcomes the inclusion of open spaces in the draft PPG. However, we do feel that the balance has tipped too much in this direction at the expense of sport provision. Furthermore, we would like to see a definition of open space, as it is not clear for planners whether proximity to parkland or countryside and accessibility of designated areas should be taken into account when deciding what open space is appropriate for a community.

  5.2  Similarly, clearer definition of sport is needed in the PPG, which at present is confusing and inconsistent. It would also be helpful if guidance can be given about the priority for a developer providing planning gain by means of open space over other demands like transport improvements. The DTLR guidance "Better Places to Live by design: a companion to PPG 3" recognises that contributions towards school places, improving public transport, libraries, community halls, medical facilities and affordable housing are also considered important and there is a need for these issues to be balanced and prioritised. This should also apply to open space and guidance given in the draft PPG.


  6.1  The Urban White Paper "Our Towns and Cities" published in November 2000 promised new planning policy guidance to put urban renaissance at the heart of the urban planning system. It also promised to improve the quality of parks, play areas and open spaces. The provision of good, accessible sport and leisure facilities must be part of this promise.

  6.2  Sport is not a statutory provision for local authorities. Funding for sport is discretionary and has for many years been declining, both in the capital funding to refurbish existing community facilities and revenue support to maintain these facilities. As referred to in paragraph 2.2 above, Sport England estimate that £3.2 billion is required to update sports facilities in England to bring them up to the standards required by a discerning public. Since Compulsory, Competitive Tendering was introduced in 1989 for sport, the private sector has been investing capital and revenue in return for management contracts for local authority facilities.

  6.3  Business In Sport and Leisure has put together examples of investment from £200,000 to £5 million and has shown that private sector expertise in participating in Best Value contracts and through Public/private partnerships has considerably enhanced both the quality and services offered in sports centres in urban and rural locations. Earlier this year, BISL ran a joint seminar with the Local Government Association on this subject for local councillors and council officials.

  6.4  The draft PPG 17 makes no mention of the Urban White Paper, nor suggests changes to the way in which planning policies will work in our towns and cities to ensure that people have access to and are encouraged to participate in sport.


  7.1  Whilst this inquiry focuses on the relationship between the draft PPG 17 and the Urban White Paper, we suggest that the Committee may also like to consider what synergies exist between the draft PPG 17 and the Government's Plan for Sport, particularly with respect to the mechanisms for delivering investment in new facilities.

  7.2  It is clear that much of Government spending will be directed towards facilities in schools under the Space for Sport and Arts scheme. School facilities are usually generally accessible to communities and are, on the whole, underused. The Committee may wish to consider mechanisms for opening up school sports facilities for wider community use.


  8.1  BISL would like to discuss the following issues with the Committee:

    —  That the draft PPG 17 is too rigid in its application of planning policies in PPG 6 and 13 in that sport and its characteristics are different from retail and other economic activity better suited to town centres.

    —  That private sector companies need to be encouraged to invest in the building of sports facilities and in their running costs in order for local authorities to make good the £3.2 billion investment required to upgrade existing facilities. The revision of PPG 17 should acknowledge this.

    —  Such encouragement needs planning policies which take account of the economic and regeneration issues and PPG 17 needs amending to this effect.

    —  That the draft PPG 17 does not pay enough attention to the Urban White Paper in looking at innovative ways of ensuring that sports facilities are included with new housing developments and in areas of deprivation.

    —  Finally, that the draft PPG 17 does not consider the wider aims of the Urban White Paper in improving the health and education of communities and reducing crime, and the contribution sport can make in this area.

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