Memorandum by Sport England (PPG 14)
1.1 Sport England is responsible for leading
and co-ordinating the development of sport in England. Our work
is shaped by the aim to have More People involved in sport, to
provide More Places to play sport and to win More Medals through
higher standards of performance in sport.
1.2 In planning terms we have two principal
Developing and maintaining the infrastructure
of sport in England.
Distributing national lottery fundsall
capital awards are dependent on successful planning permission.
1.3 Sport makes a major contribution to
society in policy areas such as health, education, quality of
life, tackling crime and social inclusion. In our evidence below,
we set out our concern that the current review of PPG 17 fails
to address this and without amendment will hinder the Government's
objective of increasing and improving the quality of sports facilities
across every community.
1.4 To be an effective and strategic planning
instrument for sport, the revised PPG needs significant improvement
in the following areas:
Inconsistencies in drafting.
Protection of playing fields.
Concise and clear national, regional
and local guidance.
2. THE CASE
2.1 Sport matters:
In the past four weeks, more than
20 million adults have participated in sport.
Evidence from OFSTED shows that schools
which take sport seriously generate faster-than-average improvements
in academic results.
Sport can unite the country behind
teams and individual competitors; with success generating a "feel-good"
factor that gives the whole nation a lift.
Sport enhances the quality of life
for millions across the country, through the pleasure of playing,
the joy of learning, and the entertainment of watching.
More than 415,000 people are directly
employed in the sports industry in the UK.
The Department for Health now encourages
GPs to prescribe sport and exercise on prescription, recognising
its vital prevention and recuperative qualities.
In 1999, the Culture, Media and Sport
Select Committee recognised that "exercise and participation
in sport help to combat social exclusion".
2.2 As the Prime Minister said when announcing
an extra £750 million was to be made available for investing
in school sports facilities:
"This is not only a sports policy . . .
it is a health policy, an education policy, a crime policy, an
Tony Blair MP, Labour Party Conference, October
3. PLANNING FOR
3.1 Since the commencement of the National
Lottery in 1995, Sport England has received 7,831 applications,
and through the 3,346 awards made to date, has invested £1.24
billion in new sports facilities. For all of this development,
planning permission was requiredtherefore the planning
system is essential to the delivery of sport.
3.2 As with any activity that requires facilities
and land use, the planning system is fundamental to sport. The
planning system must work on sport's behalf to:
protect existing facilities such
as playing fields and other sports facilities, which come under
pressure for redevelopment for non sporting uses;
promote the development of new facilities
to meet sporting needs at national, regional and local levels;
deliver new sporting facilities through
planing permissions and associated legal agreements.
3.3 The introduction of PPG 17 covering
Sport and Recreation in 1991 was the most significant achievement
ever with planning for sport. The planning system recognised for
the first time that sport was a legitimate land use in its own
right. Sport England contributed to its drafting and subsequent
implementation. For the first time there was planning guidance
which sought to ensure that adequate land, water and air resources
be created, allocated, and retained for sport at a national, regional
and local level.
3.4 In 1996 DETR and Sport England jointly
commissioned a review of the effectiveness of PPG 17. The resulting
report "The Effectiveness of Planning Policy Guidance on
Sport and Recreation" was published in 1998. The report made
36 recommendations to improve the provisions within PPG 17, including:
sustainable principles to be applied
to sports and recreation provision;
Regional Planning Guidance to identify
sport and recreational issues;
better planning for sport through
local authority development plans taking account of regional and
local sports strategies;
greater recognition and protection
to be given to open spaces;
protection to playing fields to be
clarified and strengthened; the need for local assessments;
greater use of planning obligations
to provide for sport;
clear policy for sport and recreation
in the countryside, stronger emphasis on the role of management.
3.5 More recently, a number of key factors
and public policy developments have increased the need for a revised
and strengthened PPG 17 to protect the place of sport, recreation
and open space within the planning agenda. These include:
Urban White Paper, "Our Towns
and Cities: The FutureDelivering the Urban Renaissance"
(November 2000). This fundamentally reviewed national planning
guidance, including PPG 17, in order to focus on the rejuvenation
and regeneration of our urban cities.
Rural White Paper, "Our Countryside:
The Future" (Nov 2000). This focused on the supporting rural
communities whilst looking to open up the countryside for greater
"A Sporting Future For All"the
Government's Plan for Sport (DCMS, 2000). This Plan sets out the
Government's vision for sport in the 21st century and highlights
the importance of co-ordinating sport's provision between schools,
local clubs and organisations. It includes the commitment that
an updated PPG 17 will include guidance directing local planning
authorities to produce strategies for playing fields and open
space as an integral part of their development plans.
Local authorities are currently in
the process of reviewing their development plans (as required
under the 1990 Planning Act) so that they continue to reflect
national planning policy guidance. For instance, the revised PPG
3 which seeks to increase housing development on urban (brown
field) sites, will inevitably put pressure on the availability
of land for sports use and may even put existing sport's land
under threat. To plan effectively for sport, local planning authorities
must therefore include clear policies relating to sports provision
in their development plans.
3.6 Sport England therefore welcomes and
supports the Government's intention to update and revise PPG 17.
This must happen speedily so that recent policy developments are
reflected in the local planning strategies of local authorities.
3.7 Sport England is concerned that if the
new PPG is to meet the Government's stated aims and objectives
to promote and develop sporting provision it needs clarification
and revision in a number of areas. At present the revised draft
would lead to a diminution of the role of sport and recreation
in the planning process.
3.8 To be an effective and strategic planning
instrument for sport, the revised PPG needs significant improvement
in the following areas:
inconsistencies in draftingSection
promotion of sportSection
protection of playing fieldsSection
concise and clear national, regional
and local guidanceSection 7.
4.1 The use of terminology in the draft
PPG is inconsistent. Open space is defined, but neither "sport"
nor "recreation" are similarly defined and the inter-relationship
between these uses/activities is unclear. Other undefined terms
include "formal and informal recreation" and "built
recreational facilities". Such inconsistency in terminology
will lead to problems for planning officers and inspectors interpreting
4.2 Sport England recommends the revised
PPG should include specific, defined references to "sport",
"recreation" and "open space". Sport should
be included in the titles of chapters 3, 5 and 6 to reflect the
contents of the Guidance.
5.1 The introduction to the current PPG
17 states that sports and recreation are activities with major
land use implications and refers to the national policy importance
of sports and recreational facilities.
5.2 The revised draft neither reiterates
or builds on this and also fails to reflect the very positive
approach the Government has taken to sport. It also fails to reflect
policy developments such as the recent Urban and Rural White Papers.
5.3 The new PPG 17 should paint a more exciting
picture of the growth in participation of sport, the importance
of sport to health and mental well being, and the economic and
social importance of sport to local communities.
6.1 As a statutory consultee in relation
to planning applications that involve loss of land as playing
fields, Sport England is acutely aware of the continuing pressure
for development on playing field sites.
6.2 The current PPG 17 provides clear guidance
to local planning authorities for the protection of playing fields.
Paragraphs 41-44 set out a criteria based approach for Local Authorities
to follow. This criteria based approach has been omitted from
the revised draft. This will substantially weaken the guidance
given to Local Authorities to protect their playing fields.
6.3 It is essential the new PPG provides
clear guidance to local planning authorities on the protection
of playing fields. Once lost to development these sites may never
return to recreational use.
6.4 The definition of playing fields also
needs to be revised to take account of changing trends in pitch
sports, such as the growth in popularity of the "small sided
game" (junior football) by the FA. Current definition states
the minimum area of 0.4 acre and needs to change to protect small-sided
pitches down to a size of 0.2 acre. Sport England also recommends
that the revised PPG 17 need to be expanded to include private
playing fields, extending the same level of protection offered
to other types of playing field.
7. CONCISE AND
7.1 At present the draft PPG does not provide
clear and concise advice to Local Authorities so that they understand
and can develop planning policies and an implementation programme
that is consistent with Government guidance for sport on a national,
regional and local basis.
7.2 National Planning
7.2.1 There is need for the PPG to establish
a criteria based framework for suitable sites for major events.
Some of these will be major development projects and all will
by definition have significance for sporting provision wider and
beyond the local planning authority.
The PPG should address these issues and provide
clear guidance to local planning authorities on dealing with a
criteria for site selection for projects of national significance.
7.3.1 The PPG should emphasise the need
for Regional Planning Guidance (RPG) to provide a policy framework
for the identification and delivery of major sporting venues/sites
and their protection on the basis of having regional or national
7.3.2 There needs to be a consistent approach
to the inclusion of sport within Regional Planning Guidance across
the country. The value of sport has often been missed in Regional
Planning Guidance, being overshadowed by more traditional planning
topics, such as, employment, houses and roads. RPG's need to be
consistent in recognising the part sport can play in regeneration
and developing sustainable communities.
7.3.3 The PPG should place emphasis on the
role of Sports Governing Bodies in the preparation of Regional
Guidance in order that their Sports Development Strategies can
be fully reflected in both Regional Guidance and local development
7.3.4 The PPG should provide clear advice
on the role of sport in the countryside and the need to effectively
manage sporting uses so that sports can take place in the countryside,
without detriment to the environment.
7.3.5 Sport England are developing a framework
for identifying "Significant Areas for Sport" (SASPs).
These will recognise the importance specific sites have to their
individual sports, at a national and regional level. The PPG should
require Local Authorities to recognise the sporting importance
that these sites have. SASPs of National and Regional importance
should be included in Regional Planning Guidance and Development
7.4.1 The current (1991) PPG 17 advocates
the formulation of local standards for provision of sport and
recreation. Regrettably, 10 years on very few local authorities
have completed this task and rely on national generic standards.
7.4.2 The new PPG should spur local authorities
into action. The new PPG should require local authorities to prepare
local strategies for sport and to reflect the contents of these
strategies in their development plans, through relevant policies
and land use designations. Local needs assessments should underpin
development plan policies and inform decisions on planning applications.
Topics for such strategies are playing fields and open spaces,
based on a needs assessment.
7.4.3 The new PPG should also help local
planning authorities to deliver appropriate new sporting provision
as part of the developmental process. The use of planning agreements
to secure sporting benefits should be encouraged, where new developments
give rise to increased demands on sports facilities. Furthermore,
Sport England request that Government consider granting similar
status to "affordable sport" as that currently granted
to affordable housing in PPG 3 and the accompanying circular.
This would require developers to provide, or contribute towards
public sports facilities in areas of greatest need, reflecting
the continuing land use pressure that all development places on
playing fields and sports centre sites.
8. THE ROLE
8.1. The new PPG must provide an opportunity
to ensure that the expertise and resources of Sport England are
effectively utilised to meet the Government's objectives for sport.
8.2. The draft PPG largely refers to Sport
England as a consultee on playing field matters and we envisage
this will continue to be an important part of our role.
8.3. We are also able to assist in other
areas and we suggest that PPG should refer to these in order that
all local planning authorities are fully aware of the assistance
we can offer. Specific areas and tools Sport England can assist
Playing Pitch Strategymethodology
to assess the provision of playing pitches;
Providing for sport and recreation
through new housing developmenta Good Practice Guide;
Planning Across Boundariesguide
for local sport and recreation strategies;
Facilities Planning Modelstrategic
modelling of community facilities;
A Sporting Future for the Playing
of Englandpolicy on protecting playing fields;
Planning Policies for SportSport
England's land use planning policy document; and
Detailed design advice for sports
8.4. The ability of Sport England to fulfil
its statutory objectives depends in part on a planning system
that can deliver for sport. We therefore wish to play an integral
role in the formulation and implementation of a revised planning
policy guidance note for sport, recreation and Open space.
8.5. We remain optimistic that, with the
Committee's support, the revised PPG can be strengthened so that
it can play a key role in implementing Government policy to improve
access to sporting opportunities for all.
|Particular areas of reference/interest as defined by the Urban Affairs Sub-committee
||Referred to in Sections/Paragraphs:
|The contribution of the revised PPG to strategic planning for sport, open space and recreation.
|The contribution of the PPG to the provision of high quality new open space and sports opportunities.
||Section 6, Subsections 7.3 & 7.4
|The extent to which the revised PPG is successful in addressing the newly included subject of open space and reconciling with sport and recreation.
||Section 4, paragraphs 7.3.4 & 7.3.5
|The extent to which the revised PPG's treatment of open space will contribute to the urban renaissance, the protection and improvement of open space and improved living environments.
|The contribution of the PPG to achieving the Government's aspirations on urban parks and play provision as set out in the Urban White Paper.