Memorandum by Sport England (PGS 06)
1. WHO IS
SPORT ENGLAND?
1.1 Sport England is a NDPB that develops,
promotes and invests in community sport. Our aim is to change
the culture of sport and physical activity in England in order
to increase participation across all social groups.
1.2 We strongly support the Government's
aims for sustainable communities. We believe all communities require
modern, high quality and well-managed facilities, created in step
with growth, and capable of enhancing the quality of life of residents.
Sport plays an essential part in helping to ensure the creation
of healthy, cohesive sustainable communities, particularly if
co-located alongside other vital community services.
2. RELEVANCE
OF SPORT
ENGLAND TO
THE COMMITTEE'S
INQUIRY
2.1 Sport England's goal is to increase
participation in sport and physical activity and as such we are
focussed on protecting and enhancing our sporting infrastructure.
Our role in the planning process is to offer advice to local authorities
both generally on the development of the infrastructure for community
sport and specifically as a statutory consultee to planning applications
affecting playing fields.
2.2. Sport England believes that new developments
should contribute to meeting the increased recreational needs
of our new communities through new and enhanced facilities for
sport. To this end, Sport England has actively promoted the use
of planning obligations to bring benefits for sport and recreation
through:
— Developing a web-based toolkit for
local authorities and planners. This "Planning Obligations
Kitbag" disseminates up-to-date information and tools to
support the use of planning obligations for sport and recreation
and the development of local contribution frameworks, helping
to provide an evidence based approach to policy frameworks.
— Mounting joint pilot projects to
develop new supplementary planning documents and help secure resources
from development for sport. This has been done both within the
growth areas (such as in Milton Keynes) as well as in other areas,
such as South Hams in Devon.
— Running a wide range of awareness
raising "dissemination" events within each of our regions
to encourage local authorities to use the planning obligations
mechanism for sport.
— Advising a large number of local
authorities on approaches and suitable methods for securing planning
benefits for sport. Our planning managers, operating from our
regional offices, have carried out much of this work.
2.3 As a result, we have seen considerable
progress in the development of local approaches to securing developer
contributions towards sport and recreation. A number of schemes
include standard charges and formulae geared to audits of provision
needs carried out under the guidance issued by ODPM in PPG 17
Open Space, Sport and Recreation (2002).
2.4 We have been particularly encouraged
by, and have supported, the development of tariff approaches in
the growth areas. Sport and recreation is included in the tariff
recently approved by the Milton Keynes Partnership Committee,
building on the work of our Joint Pilot Project with English Partnerships
and Milton Keynes Council.
3. NEW DEVELOPMENT
PROVIDING FOR
SPORT AND
RECREATION—EXAMPLES
OF ACHIEVEMENT
3.1 Sport England believes it is essential
to ensure that the reforms to the present system of planning contributions
enhance the sector's ability to secure facilities to meet the
additional community needs created by new development. It is critical
that the reforms do not represent a retrograde step in this regard.
3.2 Some examples of what has been achieved
through the current system of planning obligations are provided
below. These highlight how funding contributions have been secured
to meet the increased sport and recreation needs of local communities:
— Milton Keynes—£3,000 per
dwelling (approx £102 million in total if applied to 34,000
new houses) towards the provision of a swimming pool, sports halls
and playing fields and open space.
— Newcastle Walker/Riverside Regeneration
Pathfinder—£1,000 per dwelling (£3 million in
total) towards the redevelopment of the Lightfoot Leisure Centre.
— British Paper Board and Corys Wharf
Sites, Purfleet, Thurrock—£1,084,240 towards indoor
and outdoor community sports provision.
4. SPECIFIC ISSUES
RAISED BY
INTRODUCTION OF
A PLANNING
GAIN SUPPLEMENT
4.1 Sport England believes that a number
of steps need to be taken to ensure that the proposals to introduce
a planning gain supplement do not represent a retrograde step
for sport and instead boost the sector's ability to meet the sport
and recreation needs of new communities.
Direct link between the PGS and community needs
4.2 There is need for a direct relationship
between the level at which the PGS is set at, and the additional
community needs which will be generated by the new development
which is being asked to pay the PGS. Sport England believes that
the current system that limits contributions to only those facilities
which are needed to meet the additional needs created by the development,
is sound, logical and fair.
[1]
4.3 The current system is clear as to what
new development can and cannot be asked to provide and fund. The
proposed PGS needs to have similar clarity as to how the PGS will
directly reflect the cost of facilities that will be funded. Without
this direct link, the PGS simply becomes a generic tax on development
and moves away from the principle that new development should
meet the additional community needs that it creates.
PGS to be set at a level that will cover the costs
of new community needs
4.4 The PGS must be set at a level that
will fully meet the costs of the community needs that will be
created by new development. Otherwise the financial burden could
potentially fall on the Local Authority to meet this funding gap
in order for local community needs to be met. Any shortfall may
lead to a scaled down community facilities to meet the available
funding, rather than what is needed to meet the new community
needs created by the new development. This will militate against
the creation of healthy sustainable communities, well served by
appropriate facilities.
4.5 In order to set the PGS at the correct
level, an assessment of the additional needs generated by new
development throughout the country will need to be undertaken.
This may promote the establishment of a national standard of provision
for all communities. However, this is contrary to current planning
guidance that advocates local needs assessments identifying local
priorities.
[2]This contradiction
would need to be addressed.
Mechanism needed to define local infrastructure
priorities
4.6 There will be a need for new mechanisms
to define infrastructure priorities at local level. These may
be costly and time consuming to operate, and will involve difficult
trade-offs between sport and recreation infrastructure needs and
those for other aspects. Full consultation is therefore essential
in the development of these mechanisms.
4.7 In the absence of any clearer specification
of how revenues are to be recycled "directly to the local
level", the proposals offer no guarantee that land development
will be accompanied by sport and recreation provision. Indeed
the Consultation paper acknowledges that a challenge remains in
ensuring that necessary infrastructure is provided under any new
system. Local priorities will need to be established, and there
is concern that provisions such as sport and recreation may be
placed on a lower order of priority than say education or health.
Sport England believes that Government should avoid placing large
numbers of limitations, or directions on what can be provided,
in any centralised system of the sort envisaged.
Distribution of the PGS to be based on local needs
assessments
4.8 The distribution of the PGS will need
to be based on identified local infrastructure priorities, drawn
up by each Local Authority. These priorities will be set to meet
those additional community needs created by new development. These
priorities need to be established through a robust assessment
of local needs. Undertaking such assessments is already embedded
within planning guidance for sport and recreation (PPG17) and
is undertaken within the current system of section 106 agreements
and supplementary planning documents. At present, the robustness
of these assessments are tested by developers who will be party,
or subjected, to the associated costs.
4.9 Within the proposed PGS, the onus to
test the robustness of the assessment will pass onto the Treasury
(or body who will be charged to distribute the PGS). Without the
assessments being tested, the new system may encourage Local Authorities
to "over bid", in order to maximise their share of the
PGS pot.
Exemptions to be made for the development of community
facilities, and not for profit organisations
4.10 There is currently a narrow range of
exemptions to the PGS proposal. The consultation does not exempt
developments that provide significant benefits to the local community,
including sport and recreation facilities provided by public bodies
and not-for-profit organisations, such as community sports clubs.
Sport England would advocate that these organisations should be
exempt form the PGS levy.
4.11 Any additional costs will lead to poorer
facilities being developed for the local community. This will
work against the overall aim of this proposal, in providing enhanced
investment for local community facilities though the development
process.
5. CONCLUSION
5.1 Sport and recreation are already secured
substantial rewards through the existing system of planning contributions.
Sport England believes there is significant opportunity to build
on this work, ensuring that sufficient funding is provided through
new development to meet the sport and recreation needs of our
new communities. We are committed to working with local authorities
and other relevant bodies to maximise the benefits and ensure
that sport and recreation needs of our communities are met.
5.2 There is increasing evidence about the
wider benefits in terms of community health and well-being that
such investment could bring. Sport England believes that amendments
to the proposals to introduce a Planning Gain Supplement are necessary
to ensure that this these benefits can be maximised—and
not put at risk.
1 Circular 0/05 has given further clarity to the tests
that need to be applied to development. Back
2
PPG17 advises local needs assessments be carried out to identify
an areas distinctive sport and recreation needs. Back
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