Select Committee on Transport, Local Government and the Regions Memoranda

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 responsibilities:

    —  Developing and maintaining the infrastructure of sport in England.

    —  Distributing national lottery funds—all 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.

    —  Promotion of sport.

    —  Protection of playing fields.

    —  Concise and clear national, regional and local guidance.


  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 anti-drugs policy."

    Tony Blair MP, Labour Party Conference, October 2000


  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 required—therefore 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 Future—Delivering 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 recreational use.

    —  "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 drafting—Section 4;

    —  promotion of sport—Section 5;

    —  protection of playing fields—Section 6;

    —  concise and clear national, regional and local guidance—Section 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 the Guidance.

  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.


  7.1  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 significance.

  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 plans.

  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 Plans.


  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.


  8.1.  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 include:

    —  Playing Pitch Strategy—methodology to assess the provision of playing pitches;

    —  Providing for sport and recreation through new housing development—a Good Practice Guide;

    —  Planning Across Boundaries—guide for local sport and recreation strategies;

    —  Facilities Planning Model—strategic modelling of community facilities;

    —  A Sporting Future for the Playing of England—policy on protecting playing fields;

    —  Planning Policies for Sport—Sport England's land use planning policy document; and

    —  Detailed design advice for sports facility.

  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.
Section 7
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.
Section 6
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.
Paragraphs 3.5-3.8

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