Communities and Local Government CommitteeWritten evidence from the Sport and Recreation Alliance
1. The Sport and Recreation Alliance is the national alliance of governing and representative bodies of sport and recreation in the UK. Our 320 members represent 150,000 clubs across the country and some eight million regular participants. The Alliance exists to promote the role of sport and recreation in healthy and active lifestyles, to encourage a policy and regulatory environment in which sport from grassroots through to elite level can flourish, and to provide high quality services to help its members continually improve and progress.
2. Our members include the FA, the Rugby Football Union, UK Athletics, the Ramblers, British Rowing, British Gliding Association and the Royal Academy of Dance. From playing fields to rivers and leisure centres to landing strips, community clubs rely on securing sustainable access to good quality facilities for their activity.
3. This submission will principally focus on the question posed by the Committee which asks: Is the definition of “sustainable development” contained in the document appropriate; and is the presumption in favour of sustainable development a balanced and workable approach?
4. This submission will argue that the definition of “sustainable development” is the right one but that the subsequent policy in relation to delivering open space, sports and recreational facilities does not support the principle it aims to achieve.
Background
5. Current planning policy for open space, sport and recreation facilities is set out in “Planning Policy Guidance 17” (PPG 17).
6. Paragraph 10 sets out the conditions for allowing development on sport and recreation facilities:
Existing open space, sports and recreational buildings and land should not be built on unless an assessment has been undertaken which has clearly shown the open space or the buildings and land to be surplus to requirements. For open space, “surplus to requirements” should include consideration of all the functions that open space can perform. Not all open space, sport and recreational land and buildings are of equal merit and some may be available for alternative uses. In the absence of a robust and up-to-date assessment by a local authority, an applicant for planning permission may seek to demonstrate through an independent assessment that the land or buildings are surplus to requirements. Developers will need to consult the local community and demonstrate that their proposals are widely supported by them. Paragraph 15 below applies in respect of any planning applications involving playing fields.
7. Paragraph 13 sets out how the planning authorities should aim to achieve improvements to the accessibility of sport and recreation facilities:
Equally, development may provide the opportunity to exchange the use of one site for another to substitute for any loss of open space, or sports or recreational facility. The new land and facility should be at least as accessible to current and potential new users, and at least equivalent in terms of size, usefulness, attractiveness and quality. Wherever possible, the aim should be to achieve qualitative improvements to open spaces, sports and recreational facilities. Local authorities should use planning obligations or conditions to secure the exchange land, ensure any necessary works are undertaken and that the new facilities are capable of being maintained adequately through management and maintenance agreements.
8. The overall aim of PPG 17 is to ensure that the stock of valued sport and recreation facilities is not diminished and, if necessary, improve the accessibility of sport and recreation facilities where it does not meet the needs of communities.
“Sustainable Development”
9. Paragraph 9 of the draft NPPF states that:
The purpose of the planning system is to contribute to the achievement of sustainable development. Sustainable development means the development that meets the needs of the present without compromising the ability of future generations to meet their own needs.
10. One of the “needs” identified in paragraph 10 is that sustainable development should support communities “health and wellbeing”. The Alliance believes this approach is sensible not only from a social perspective but also from an economic one. According to research by the Department of Health the cost of physical inactivity to the nation is estimated at £8.3 billion. This does not include the cost of overweight and obesity, which is estimated at £7 billion.
Deliver Open Spaces, Sports and Recreational Facilities
11. In relation to the delivery of open space, sports and recreational facilities paragraph 128 retains many of the policy requirements contained in PPG 17 with emphasis meeting the “health and wellbeing” needs of communities. Is states that:
Access to good quality open spaces and opportunities for sport and recreation can make an important contribution to the health and well-being of communities. The planning system has a role in helping to create an environment where activities are made easier and public health can be improved. Planning policies should identify specific needs and quantitative or qualitative deficits or surpluses of open space, sports and recreational facilities in the local area. The information gained from this assessment of needs and opportunities should be used to set locally derived standards for the provision of open space, sports and recreational facilities. Planning policies should protect and enhance rights of way and access.
12. Paragraph 128 goes on to state the conditions for when to allow sport and recreation facilities to be built on. They should not be built on unless:
an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or
the need for and benefits of the development clearly outweigh the loss.
13. The first bullet point supports sustainable development as it is based on the needs of the community. The second bullet goes against the spirit of sustainable development because it will promote the erosion of valued sport and recreation facilities and the reduction of replacement facilities being provided by developers.
14. Current planning policy allows sport and recreation facilities to be built in certain circumstances but also require the substitution of one site for another (see paragraph 7). This approach ensures that the needs of communities are not neglected and the stock of valued facilities is not eroded.
Critical Times for Community Sport
15. Open space, sport and recreation facilities have traditionally been given stronger protection by planning policy to reflect the public benefits they provide. Yet community sport is in a perilous state—a shift away from the protection of local facilities could be fatal. The Sports Clubs Survey 2011 (to be released, 14 September 2011)
A quarter of sports clubs use a public space to play their sport (down from a third in 2009); only one in five clubs own a facility.
The average club’s annual surplus has fallen by almost half in three years to £1,091.
Average income is falling, and more than a quarter of clubs are running at a loss. 95% of clubs operate on a not-for-profit basis.
Membership fees account for a third of a typical club’s income, but there is real possibility that the trend in declining adult membership will continue.
Local authority and educational establishments currently provide half of all playing facilities.
Conclusion
16. The draft NPPF aims to promote sustainable development but gets the balance wrong in its aim to deliver open space, sport and recreation facilities to meet the needs of communities. The Alliance asks the committee to recommend looking again at the balance in favour of sustainable development in relation to open space, sport and recreation facilities, to protect clubs who can not compete in pure economic terms with other forms of development. Increased emphasis on protecting and providing valued facilities to enable increased levels of physical activity would allow community clubs a fighting chance of growing their sport. In particular we ask the Committee to recommend that the national planning policy framework states that, if community sports facilities or public space are developed, then an equivalent or better provision is provided elsewhere as part of the development.
September 2011