National Planning Policy Framework

Written evidence from the Football Association

This submission is The Football Association’s response to the call for evidence from The Communities and Local Government Committee on the draft National Planning Policy Framework.

If the Committee would like any further information, please feel free to contact Robert Sullivan, Head of Public Affairs for The FA Group, whose contact details are included in our introductory letter.

1.0 Introduction

2.0 Issues arising from proposals within National Planning Policy Framework, (NPPF)

3.0 Questions

4.0 Conclusion

1.0 Introduction

The Football Association (The FA) is the governing body for football in England. It takes the lead in providing a framework for English football and is responsible for regulating, promoting and developing the game at every level, both on and off the field. Every month nearly seven million people play some form of the game including 3.9 million children. There are 131,000 FA-affiliated teams playing in over 1,200 leagues with over 400,000 volunteers helping the game run smoothly. As football’s national governing body, The FA aims to ensure that everyone can have the chance to be actively involved in football in a safe, positive, high quality environment where they are given the appropriate support to be the best they can.

In 2008 The FA launched its National Game Strategy which sets a series of challenging targets for the development of the grassroots game; this work is supported by an FA-led investment programme covering all aspects of the game. A significant element of this investment has been directed towards facilities, mainly through the Football Foundation. The Football Foundation was established in 2000 as a charitable vehicle dedicated to the delivery of improved programmes and facilities within the grassroots game. It is funded by three partners, The Premier League, Sport England and The FA who through their combined investment have secured projects with a total value of close to £1bn over that period. It continues to be a significant contributor to grassroots facilities.

Latterly, the Football Foundation has concentrated on capital/facility improvements reflecting a growing demand within the grassroots game for improvements to facilities and the development of new facilities to support growth.

Football’s grassroots game is very heavily dependent on publicly owned and managed facilities. Over 84% [1] of football is played on publicly owned playing pitches/facilities. Consequently, The FA has always taken a very close interest in planning policy as any changes have the potential to impact significantly on the game at community level.

Over the past decade, playing fields have enjoyed some protection from planning applications through Sport England’s role as statutory consultee for all planning applications impacting on wider sporting provision. The FA has fully supported Sport England in this role and currently works very closely with Sport England planners to ensure that grassroots football’s interests, wherever possible, are protected.

This robust and public-centred defence of playing fields has been welcomed across grass-using sports and the public alike, but it has only been made possible through a strong Government-led position seeking to secure the protection of public playing fields. It is The FA’s view is that there has to be a robust assessment of developments impacting on sports facilities. This is currently carried out by Sport England as a statutory consultee and we believe that they are well placed to offer an independent and objective assessment of developments impacting on existing sporting infrastructure and that their statutory consultee role should prevail, supported by strong policy content predicated on the protection of existing community sporting provision. Furthermore, Sport England has developed specific expertise and sophisticated demand and supply analysis tools which have been widely accepted across the planning and sport community alike. It is essential that any planning decisions affecting local community sporting infrastructure are properly assessed within the context of this expertise so as to ensure genuinely sustainable development.

The Football Association considers that the proposals put forward as part of the National Planning Policy Framework place playing fields and facilities at great risk, in favour of broader development aspirations, and in so doing, reduce opportunities for future generations to participate in their national game and, more generally, for the public to participate in healthy sport. Football growth, as seen over the past decade will simply not be possible without a protected and sustained national network of playing fields, free from threat of development.

2.0 The National Planning Policy Framework

The FA fully endorses the formal response made to this consultation by Sport England and in particular their assessment that the proposed consultation document significantly weakens the protection of national sporting infrastructure and potentially undermines their important role as statutory consultee.

The FA supports Sport England’s proposition that there must be provision made in the framework for the following key areas:

· Statutory Consultation through Sport England - Strong policy content requiring protection of existing sporting infrastructure as a starting position in any planning considerations and that any deviations/reductions in local sporting infrastructure only be approved subject to independent evidence to support a case of over-supply or where appropriate equivalent sporting provision might be provided in lieu of the development. Furthermore, that any planning proposals that have the potential to impact on existing sporting infrastructure be subject to Sport England’s independent assessment utilising the widely accepted tools to determine accurate demand models.

· Definition of Community Infrastructure – The Football Association believes that sports facilities have a significant and important part to play in the evolution of sustainable communities. The framework document does not currently explicitly refer to this aspect of community infrastructure which may in turn lead to a failure on the part of local planning authorities to consider sufficiently the contribution made by community sport to sustainable development. Whilst it is recognised that many local authorities will consider these needs, The FA would recommend that these considerations are explicitly referred to within the framework such that local authorities are required to determine specific local need and make appropriate provision subject to Sport England approvals. The sophistication and depth of local data available in sport has developed significantly over the past decade to the extent that most major sporting bodies (NGBs) and indeed Sport England, will be able to provide clear, unambiguous demand models at a local level to support decisions to include sporting infrastructure as part of forward planning exercises. A requirement to ensure community sporting infrastructure is properly considered need not result in unnecessary delay or expense and will strengthen a local authority’s planning strategies.

· The wider societal role of sport – The FA recognises that the framework acknowledges the wider benefits accrued through sport, specifically regarding health and well-being. Whilst difficult to prove on an objective level, The FA considers that sport has the ability to deliver a far broader range of benefits to local communities - economically, environmentally and socially. Football in particular is a driving force in identifying, developing and sustaining community volunteers, whether they be parents, coaches, referees or administrators. The community benefit of this combined voluntary workforce offers a significant added-value to local communities – economically as well as socially. Simply put, grassroots football in England relies on over 400,000 volunteers all of whom are reliant on a sustainable and protected community facility base. Similarly, future community-volunteers engaged through football will rely on access and availability of public playing field space and facilities. The Football Foundation has very recently carried out independent research identifying that almost 60% of adults questioned confirmed their belief that improved community sport facilities would result in a decline in anti-social behaviour. 40% of those questioned suggested that improved community facilities would ‘generate community pride’ [2] .

3.0 Questions

3.1 Does the NPPF give sufficient guidance to local planning authorities, the Planning Inspectorate and others, including investors and developers, whilst at the same time giving local communities sufficient power over planning decisions? The current proposals, whilst reducing complexity and content, also introduce a level of ambiguity into the overall planning process in so far as planning for sport is concerned. It is understood that due consideration may be given to those communities directly affected by planning proposals being able to express their own planning outcomes. However, The FA feels that ambitions for local accountability would be improved further if specific, concise guidance was made available to support local decision making. Such guidance should include an explicit section outlining the minimum considerations to be afforded to community sporting infrastructure. This would ensure that local decisions were taken in light of all considerations without re-creating a bureaucratic and unwieldy planning framework – local discretion could still be imposed but within some defined and necessary protections for community sport.

3.2 Is the definition of ‘Sustainable Development’ contained in the appropriate document; and is the presumption in favour of sustainable development a balanced and workable approach? The Football Association fully supports Sport England’s response that there is an imbalance between economic drivers and social/environmental drivers regarding planning considerations. Whilst economic pressures are fully understood, genuinely sustainable development can only be achieved long term if, at the outset, proper and thorough consideration is given to wider community outcomes.

3.3 Are the core planning principles clearly and appropriately expressed? The FA fully supports Sport England’s response on this question.

3.4 Is the relationship between the NPPF and other national statements of planning policy sufficiently clear? The FA is not in a position to comment on this issue.

3.5 Does the NPPF serve to integrate national planning policy across Government Departments? The FA believes that a new national planning framework provides a unique opportunity to compel an element of cross-departmental collaboration designed to ensure that the planning output requirements of health, education, private sector, sport and others are combined to achieve economies of scale but also again, to ensure the best possible chance of securing genuinely sustainable development. Community sport should play a full part in this.

3.6 Does the NPPF, together with the ‘duty to co-operate’ provide a sufficient basis for larger-than-local strategic planning? No comments.

3.7 Are the policies contained within the NPPF sufficiently evidence based? As already mentioned in this response document, The FA recognises the expertise built up by Sport England through various analytical tools that in themselves provide robust evidence to support planning decisions. These techniques are well understood by the sporting sector and developers alike. The confidence in these tools should be protected and invested in further to ensure that policy decisions arising from this new framework are evidence-based.

4.0 Conclusion

The Football Association fully recognises the importance of a planning system that is able to maximise investment opportunities and at the same time, create accountability within those communities directly affected. However, there should be robust safeguards in place to ensure that wider considerations are not overlooking in a drive for economic outcomes. A community that is genuinely sustainable is one that has a long term vision and direction. That same long term vision in any community should recognise the social, environmental and economic benefits that are derived from community sport.

Football in England has a huge part to play in this – it is after all, the national game, with a huge following at all levels. As a sport reliant on public playing fields and facilities, The FA considers its future development potential to be inextricably linked to Government planning policy. A new National Planning Policy Framework therefore presents an ideal opportunity to ensure that community sport is protected not just for current participants, but those of future generations.

However, as the proposals currently stand, The FA considers that community sport is not adequately protected and place playing fields/facilities at great risk, and in so doing, reduce opportunities for future generations to participate in their national game and, more generally, for the public to participate in healthy sport.

The Football Association

September 2011