Communities and Local Government CommitteeWritten evidence from Sport England

1. Sport England

Investment into Sport

1.1 Sport England is the NDPB responsible for creating a world-leading community sport system of clubs, coaches, facilities and volunteers. We invest both National Lottery and Exchequer funding in national partners and community projects to build the sporting infrastructure that will grow and sustain participation in grassroots sport and create opportunities for people to excel at their chosen sport. Since 1995, the National Lottery has invested £1.74 billion in 5,400 awards to sports facilities with a total project value of £3.85 billion.

1.2 Over the next three years we will invest over £800 million into sport in England. The new decade offers unrivalled opportunity to grow participation in sport and physical activity inspired by high profile international events—London 2012 Olympic and Paralympic Games; 2013 Rugby League World Cup; 2015 Rugby World Cup; and 2019 Cricket World Cup. In addition, we will roll out the Olympic Legacy Pan—Places People Play; the facility element of these programmes comprises an investment of over £90 million, which will help to stimulate community sport and increase participation. The programmes are Protecting Playing Fields (£10 million), Iconic Facilities (£30 million) and Inspired Facilities (£50 million) In addition to this investment, Sport England works with local authorities, key investors in local sporting opportunities, to support them deliver these opportunities in the current economic climate where they face challenging choices about local priorities and investment, including rationalisation and asset transfer of sport and recreation facilities.

1.3 It is essential that this investment in the “decade of sport” is underpinned by a planning system that positively contributes to providing and protecting a legacy of sustainable, local community based sports facilities in which people are encouraged to participate.

Sport England—and the planning system

1.4 Sport England continues to play an active role in today’s planning system through its role as a statutory consultee on planning applications that affect playing fields and advising local authorities on other developments that effect sport facilities. We have also helped to shape planning guidance for sport and recreation by contributing to the drafting of PPG17 in 1991 and 2002.

1.5 Sport England has been a statutory consultee for planning applications affecting playing fields since 1996, after concerns by Government about the unchecked loss of playing fields. Sport England has adopted a policy which opposes the loss of playing field land unless the proposal meets one of five exceptions. This policy has allowed Sport England to check the loss of playing fields whilst ensuring improvements, replacements and increasing opportunities to sport and recreation. In 2008–09, 1,181 out of 1239 (95%) concluded planning applications affecting playing fields resulted in improved or safeguarded sports provision. This policy has shown that development can be accommodated whilst protecting and improving sports provision.

1.6 Sport England has been able to utilise the strong Government policy position to minimise the losses of areas of playing field very effectively. It must be stressed, however, that although current policy is strong and rigorously applied, most developments are not delayed, as they meet one of the exceptions of Sport England’s playing field policy, Where Sport England initially objects, we typically manage to negotiate a better deal for sport in 50% of cases, allowing us to withdraw our initial objection.

1.7 We continue to believe that in order to ensure that the current and future sport and recreational needs of their communities are fully met, local authorities must have a strong needs and evidence base on which they can plan properly.

1.8 Sport England has developed a range of advice, resources and tools to help local authorities achieve this. These include, the Active Places facilities data base, the Active People Participation survey, Market Segmentation tool, Planning Kitbag, Sport Facilities Calculator, Facilities Planning Model, Playing Pitch Strategy methodology, Facilities Improvement Service and the Active Design Guide.

2. The National Planning Policy Framework Consultation

2.1 Sport England considers that the proposed consultation document, significantly weakens the current protection on sports facilities and undermines Sport England’s Playing Field policy; should be stronger at promoting the need for a strong evidence base to underpin infrastructure planning for sport; and, provide far greater recognition of the wider benefits that sport brings to society.

2.2 Sport England believes that the current draft NPPF would create a planning system that would not protect sports facilities from being lost to development and also provide no guarantee that sports facilities that are needed to meet the sport and recreational needs generated by future generations would be secured. Ultimately, this will lead to the reduction in the stock of sports facilities.

2.3 Three principal changes that should be made to the NPPF are:

(a)Protection and Enhancement—To continue the current strong policy statements supporting the protection and enhancement of sports facilities.

(b)Planning for Community Infrastructure Needs—To continue the current requirement for a robust needs and evidence base to underpin policy and plans to securing communities sport and recreational needs.

(c)Recognition of the wider benefits of Sport—Increased recognition of the wider benefits that sport and recreation play in delivering economic and social objectives.

(a) Protection and Enhancement

Sport England believes that the draft NPPF significantly weakens the current protection afforded to sports facilities, including playing fields, as currently set out in PPG17, and undermines Sport England’s role as a statutory consultee on developments affecting playing fields.

Issue with the draft NPPF

2.4 The proposed policy (Draft NPPF paras 128 and 129) only requires that a) specific needs and deficits or surpluses of open space, sports and recreation facilities in the local area should be identified and b) this assessment should be used to set local standards for the provision of open space, sports and recreational facilities.

2.5 There is a presumption that no building should be allowed that would affect these facilities (including playing fields) unless an assessment has shown them to be surplus to requirements. However, even where a surplus has not been identified and a deficiency exists, the NPPF would now not require any replacement provision to be provide if “the need for and benefits of the development clearly outweigh the loss” (para129, second bullet).

2.6 Between 2001 and 2009, 15% of all applications which Sport England were consulted on as a statutory consultee, and were subsequently approved by the LPA, resulted in replacement playing field provision being secured. As currently worded, the NPPF would not guarantee that this replacement provision would be secured and would lead to a net loss of playing fields in these cases.

2.7 The proposed wording raises a major concern that, where development opportunities are limited, developers will argue that the need for development eg housing outweighs the loss of sports facilities. This will especially apply in densely developed areas such as, London, where demand for housing will always outstrip supply.

2.8 This situation could also be exacerbated in the current economic climate where local authorities are looking to maximise returns from their assets. Those sports that rely on local authority or education owned sites, will be particularly vulnerable to loss. For example, 84% of all football pitches in the country are in education or local authority ownership.

2.9 Sport England considers that as the wording of the draft NPPF currently stands, it will lead to a steady erosion of sports facilities without a requirement for providing any replacement or compensatory facilities to mitigate the loss. This will have the impact of undermining past, current and future investment into sports facilities, including the current Olympic Legacy programmes.

Proposed Change to NPPF

2.10 The policy in paragraph 129 should be amended to provide clear protection of facilities for sport and active recreation. The revised wording for paragraph should become:

Paragraph 129

Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:

an assessment has been undertaken which clearly shows there to be surplus; or

the loss as a result of the proposed development would be replaced by equivalent or better provision, in terms of quantity and quality in a suitable location; or

the need for the alternative open space, sports and recreation development clearly out weighs the loss.

(b) Planning for Community Infrastructure Needs

Sport England believes that the draft NPPF needs to have greater clarity on how the planning system will plan for community infrastructure.

Issues with NPPF

2.11 Community infrastructure—Sport England supports the approach of local authorities setting out their strategic approach for community infrastructure, as set out in the Plan-making section of the draft NPPF. However, the draft NPPF needs to have greater clarity on what is included within community infrastructure, being explicit that sport and recreation forms part of community infrastructure. For instance, paragraph 31 should be made clear that infrastructure requirements also includes community infrastructure. The current wording of paragraph 31 is confusing, as it includes other physical site infrastructure together with some social infrastructure, such as health and social care, which overlaps with paragraph 38.

2.12 Evidence base—The draft NPPF has watered down the need for a strong evidence base to underpin policy making. Paragraph 27 of the draft NPPF asks local authorities to base their Local Plans on adequate, up-to-date and relevant evidence, where the previous PPG17 required robust assessments of the existing and future needs of their communities for open space, sport and recreation. Sport England believes that the standard and robustness of the evidence base should not be reduced, and the better the evidence is, the more informed and ultimately better policy and planning decisions will be achieved. Decisions made on minimal information can be extremely costly in both losing facilities that are needed, and allowing investment to take place in the wrong location.

2.13 Standards Approach—Paragraph 128 states that the information gained from the assessment of needs and opportunities should be used to set locally derived standards for the provision of open space, sport and recreation. Local assessments will provide the basis on which local delivery infrastructure plans can be produced. This approach would accord with the requirements of the CIL which should use the infrastructure planning underpinning the development plan to identify specific infrastructure projects. However, the use of assessments of need to set standards, as proposed by the NPPF in paragraph 128 for sport and recreational provision, will not provide the more detailed infrastructure planning that is required for CIL that is promoted in by the NPPF for other types of provision.

2.14 Sport England is concerned that any approach to set strategic policies for community infrastructure for an area, using evidence from assessments of need to calculate standards or carry out more detailed infrastructure planning, could be undermined by the draft NPPF’s priorities towards development.

2.15 Economic Priority—Paragraph 41 of the draft NPPF states that in order to be appropriate the cumulative impact of these standards and policies should not put the implementation of the development plan at serious risk, and should facilitate development throughout the economic cycle.

2.16 This effectively means that even where community infrastructure priorities have been identified within a local area through a robust evidence base, to support the development plan, these may be dropped if they are likely to impact on the viability of economic development. This presents the risk that future developments will not be supported by the level of associated community infrastructure which given the wide benefits of such provision will undermine the development of successful and sustainable communities.

Changes to NPPF

2.17 Community infrastructure should be more explicitly defined within the NPPF, and should include sport and active recreation.

2.18 Paragraph 31 should be more clearly defined, with either the inclusion of community infrastructure, or community infrastructure requirements are added as a separate heading within the evidence base section.

2.19 Paragraph 27 should require that all evidence should be robust and comprehensive.

2.20 Paragraph 128 should be amended to read:

“The information gained from this assessment of needs and opportunities should be used to produce locally derived infrastructure delivery plans”.

(c) Wider benefits of sport

Sport England believes that the draft NPPF should be stronger in recognising the wider benefits sport and physical activity can bring to society and the role sport plays in meeting government agendas.

Issues with the draft NPPF

2.21 Sport England welcomes the reference the NPPF makes to the contribution sport and recreation makes to the health and well-being of communities (NPPF para 128). In addition, sport brings wider benefits to communities and individuals, which along with improving health and well being, also contributes to: increasing skills, employment and economic growth; increasing community cohesion and providing new opportunities for children and young people.

2.22 In its current drafting, the NPPF does not recognise these wider benefits that sport brings, many of which were included in the current PPG17. When developing planning policies and determining applications, the wider benefits that sport brings need to be adequately taken into account. For example, this would be particularly important when considering proposals against the current wording of paragraph 129 of the draft NPPF.

Changes to the draft NPPF

2.23 Sport England considers that the core planning principles should include an additional core principle that ensures development should promote a sense of place and neighbourhood and building cohesive and inclusive communities.

2.24 Sport has a significant role to play in helping to achieve this additional principle, by contributing to a wide range of government agendas, including health and well-being, building strong communities and neighbourhoods as well as contributing to economic growth of the country.

2.25 Paragraph 128 should also include the wider benefits that sport can bring to society, alongside health and well being.

2.26 The NPPF needs to give greater recognition to the wider benefits sport and physical activity can bring to society and the role sport plays in meeting cross government agendas.

(See appendix for more details on the wider benefits of sport)

3. Committee Questions

Does the NPPF give sufficient guidance to local planning authorities, the Planning Inspectorate and others, including investors and developers, while at the same time giving local communities sufficient power over planning decisions?

3.1 Reducing around 25 Planning Policy Guidance notes (PPG) and Planning Policy Statements (PPS) into one single document will mean that there is a reduction in detailed guidance. Although the streamlining is welcome in some areas, it is likely to lead to reducing consistency in planning decisions with the potential of increasing the number of planning appeals, as applicants and local authorities strive to interpret areas of the NPPF. This in turn may defeat one of the objectives of the streamlining of guidance by slowing down the planning process through an increase in appeals.

3.2 Sport England considers that the detailed guidance contained in PPG17 has been essential in supporting Sport England’s playing field policy, through its role as a statutory consultee for developments affecting playing fields, and also to ensure local needs assessments for sport and recreation are carried out by local authorities.

3.3 Sport England believes that it would be useful for CLG to issue a statement to clarify whether it will produce good practice to accompany certain elements of the NPPF or encourage other national bodies to do so. This could help bridge the gap in relation to the lack of detailed guidance in the NPPF. Sport England would welcome the opportunity to work with CLG to help produce such a guide. However, this will need clear policy presumptions concerning the protection and enhancement of sports facilities to be in the NPPF.

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?

3.4 Sport England does not believe that as worded the NPFF gives a balanced approach to sustainable development and therefore does not meet the concept as defined in the Bruntland report.

3.5 Although paragraph 10 suggests that sustainable development means planning in terms of economic, social and environmental role, the thrust of the document is that the economic goals override the social and environmental ones. Examples of this include:

Para 13—“significant weight should be placed on the need to support economic growth through the planning system”.

Para 14—Promotes a pro-development agenda, without any counterbalance in relation to its impacts. This is demonstrated by bullet point 4 “grant permission where the plan is absent” and the final paragraph which states that “all of these policies should apply unless the adverse impacts of allowing development would significantly and demonstrably outweigh the benefits”. This last statement would suggest that developments that do have adverse impacts on local communities (social and environmental) will be allowed, with only those being deemed “significant” being questioned.

Para 17—This suggests that neighbourhoods should support objectives which seek to promote growth, but is silent on setting out policies to protect and enhance locally important facilities which meet environmental and social objectives;

Para 129—This suggests that even where a deficiency of open space, or sports facilities has been identified (social and environmental) the need for a development (economic) can outweigh the loss of the open space, or sports facilities.

Are the “core planning principles” clearly and appropriately expressed?

3.6 Sport England considers that the core planning principles should include an additional core principle that ensures development should promote a sense of place and neighbourhood and build cohesive and inclusive communities. Sport has a significant role to play in helping to achieve this additional principle, by contributing to a wide range of government agenda’s, including health and well-being, building vibrant communities and neighbourhoods as well as contributing to economic growth of the country.

Is the relationship between the NPPF and other national statements of planning-related policy sufficiently clear?

No comment.

Does the NPPF serve to integrate national planning policy across Government Departments?

3.7 Sport England does not believe that the NPPF sufficiently seeks to integrate national planning policy across Government Departments. An example of this is with Sport England’s parent department DCMS, in that aside from sport and heritage there is a lack of reference to policies in relation to the arts, libraries etc. There is also no recognition of the wider benefits that sport brings to communities improving health and community cohesion, increasing skills, employment and economic growth, and providing new opportunities for children and young people.

3.8 With regard to sport, Sport England is concerned that the Olympic Legacy and investment in new sports facilities via the lottery will be undermined by a lack of protection for existing facilities through the planning system.

Does the NPPF, together with the “duty to cooperate”, provide a sufficient basis for larger-than-local strategic planning?

No comment.

Are the policies contained in the NPPF sufficiently evidence-based?

3.9 Sport England believes that robust policies and planning decisions should be built on a sound and robust evidence base, so ensuring that the right development takes place in the right location. As a result of this, we have developed a number of tools and techniques over the years, such as the Facilities Planning Model, Sport Facilities Calculator, Facilities Improvement Service and Playing Pitch Methodology to achieve this. The current PPG 17 supported this in paragraph 1 by stating that “Local authorities should undertake robust assessments of the existing and future needs to their communities for open space, sports and recreational facilities”.

3.10 Sport England believes that this approach has been fundamentally undermined within the new NPPF. The need for “robust” assessments has been removed in Paragraph 128, whilst Paragraph 129 seeks to undermine the assessment of needs in Paragraph 128 by allowing for the needs of new development to override such assessments even if a deficit has been identified. In addition, there is now no requirement to provide any like for like replacement or compensatory provision for the loss of any sports facilities.

3.11 The use of assessments, development of standards and priorities via an evidence based approach is further undermined in Paragraph 41 which states that “In order to be appropriate the cumulative impact of these standards and policies should not put implementation of the development plan at serious risk, and should facilitate development throughout the economic cycle”. This effectively means that even if local priorities have been identified for funding via CIL, based on an evidence based approach, they may have to be dropped if they are likely to reduce economic development. The result of which will be that the future communities will be developed without the required associated community infrastructure that makes development into cohesive and healthy communities.

3.12 Sport England is therefore concerned that the approach to downgrade the importance of evidence based planning will not only mean that existing facilities will be lost but also reduce the potential for much needed new facilities and social infrastructure to be funded and delivered through CIL.

September 2011

APPENDIX

Wider Benefits of Sport

These benefits include:

(a)Building communities through local pride and success/improving social cohesion.

(b)Improved health of communities.

(c)Value to the economy.

(a) Building communities through local pride and success/improving social cohesion

Ensuring communities, families and young people have good quality places to play sport is important for the pride and sense of place felt by people in their communities. Sport, through its many clubs and volunteers, has a contribution to make to the Big Society and a community’s sense of place. Sport is the number one choice for volunteering with 52% of adults who volunteer doing so in sport. For some communities this may mean getting involved in running their own facilities as part of a community asset transfer scheme or as a social enterprise.

Sport has the ability to bring different groups together and build strong relationships and networks, creating happier more tolerant communities. A vibrant club or sporting group can help diverse groups of people come together with all the benefits that working as a team can bring.

Nationally, the cost of responding to incidents of anti-social behaviour is £3.4 billion per year. It is widely accepted that to achieve a reduction in anti-social behaviour and in the fear of crime a combination of factors is required. Within this sport is recognised as having an important part to play. Sports activities and competitions, sports volunteering, sports leadership, sports training and sport employment schemes help develop individuals and communities, encourage healthier and more productive lifestyles and create inclusive communities and neighbourhoods that provide a shared identity and sense of place.

Research has found that the activities young people engaged in had a significant additional association with their chances of later adult social exclusion. It concluded that to reduce the likelihood of exclusion in later years young people should be engaged in a combination of activities, within which sport makes an important contribution.

(b) Sport’s role in improving the health of the nation

Many studies have shown that physical activity and sport save, extend and improve the quality of lives. Those who are physically active have reduced risk of heart disease, strokes, type II diabetes and different forms of cancer. There is also compelling international evidence that demonstrates the impact of exercise as a treatment as well as a preventer of ill health reducing the need for expensive drugs, and potentially adding years to life.

Physical activity and sport can also be a powerful enabler for those with physical disabilities, offering them opportunities to be more mobile and to build their confidence, which as well as improving health and quality of life, can reduce the need for carers and support.

Mental wellbeing may also be enhanced through increased physical activity and sports participation. The reduction of anxiety and depression, counteraction of loneliness through the promotion of social contact, and increased confidence and self-esteem, reduce what is currently a significant burden on mental health budgets.

Not only does physical activity and sport deliver significant public health benefits, it also has the potential to save the tax payer over £3 billion a year in avoided healthcare costs . Research has shown that a million more people across the country playing sport each week would save the taxpayer £22.5 billion in health and associated costs. For example, the health gains associated with a 30–49-year-old who plays football are valued at £27,600 (over the lifetime of the individual).

(c) Sports value to the economy

Growth in the sport sector has outstripped the English economy as a whole over the past two decades, according to research published in August 2010.

The sport economy’s annual contribution has reached £16.668 billion—up 140% in real terms between 1985 and 2008.

The research was commissioned by Sport England and carried out by the Sport Industry Research Centre at Sheffield Hallam University. The researchers found that growth between 2005 and 2008 was “driven by investment directed towards the London Olympics and a long-term Sport England policy to increase sport participation”. They argue that sport’s resilience reflects the growing number of people who “consider sports participation as being more a basic need than a luxury”.

Other key findings of the report, The Economic Value of Sport in England include:

Consumer spend on sport in England was £17.384 billion in 2008—up 138% since 1985.

The number of people with sport-related jobs has also grown, reaching 441,000—that’s 1.8% of all employment in England.

Over three-quarters of these jobs are in the commercial sector, with 13% working in the public sector.

The report also compares the value of the sport sector across the country. It finds that London makes the largest contribution, reflecting the size of the capital’s economy. However, per capita spending on sport is greatest in the east of England at £404.

Prepared 20th December 2011