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Policy

FIT is the leading body on policy relating to recreational land protection. We have our own method of protecting land directly through charity, contract and land law. We also interpret Government policy on recreational land protection in the UK (see Planning Policy Guidance), advise the public on government policies and lobby and advise the Government and Country Assemblies on policy campaigning to improve Government and Assemblies' policy.

Recent campaign successes include the strengthening of legal protection for School Playing Fields in England, financial relief for community amateur sports clubs - specifically including 80% mandatory rate relief - and the inclusion of charitable status for the promotion of sport in the new Charities Act.

Campaigning

FIT campaigns for changes in law as mentioned above at Westminster, in Cardiff and in Edinburgh. We also lobby MPs and influential bodies such as the London Assembly for their co-operation and support.

At a local level, FIT supports local campaigners working to save fields under threat with its Ten Step Guide and in collaboration with other bodies such as the County Playing Fields Associations (CPFAs) and Planning Aid.

FIT campaigning is currently focused on the following in England:

Community Fields Statutory Protection

FIT believes that community fields (as opposed to school playing fields) should enjoy the protection that has been afforded to school fields since 2004. We propose any application to change the use of, or sell, playing fields used by schools in the last 10 years and of at least 0.2 hectares in size should be scrutinised by an independent Government panel. This panel will then make recommendations prior to Ministerial decisions. Each application should be judged against criteria relating to current site use, potential site use, other local facilities and the reinvestment of the proceeds of sales in new sports and leisure facilities, with priority given to the improvement of outdoor facilities for sport and play.

It is important to note the current definition of a playing field refers to site marked out for competitive pitch sports of at least 0.4 hectares. This leaves countless sites of under 0.4 hectares or of a greater size but without marked playing pitches on them. In these cases, the only protection available is members of the public battling with a complicated and expensive planning system. It is not surprising that FIT hears of an average of five threats a week to community playing fields. Government policy in PPG17: Planning for Open Space, Sport and Recreation and the policy of Sport England are based on a presumption against the development of playing fields.

FIT believes exceptions can be made, such as development which improves site facilities or replaces lost facilities. There are, however, two policies which need changing.

Areas of land which are smaller than a pitch (defined as 0.4 acres) are capable of exception and this needs changing. Of greater concern is that exception can be made on the basis that Sport England considers that there is a gain for sport. This is criticised on two counts – subjectivity and if proceeds are used for indoor sports facilities to the detriment of much needed outdoor facilities.

The rules vary in the other countries of the UK – please see the table below for a summary:

Planning Policy Guidance in England, Scotland & Wales:

How do they compare?

Introduction

There are currently three important documents covering planning policy for open space, sport and recreation in England, Scotland and Wales.  They are:
The comments are given below as E, S or W meaning
• Planning Policy Guidance 17: Planning for Open Space, Sport and Recreation, published July 2002 (for England)
• Consultation on Scottish Planning Policy 11: Physical Activity and Open Space, closing date 3 November 2006
• Technical Advice Note 16, Sport, Recreation and Open Space, a draft for consultation, closing date 27 October 2006

Underlying Principles

England

PPG17 is set within the context of the Government’s broader planning objectives, relating to urban renaissance, rural renewal, social inclusion and social cohesion, health and well-being and sustainable development in England

Scotland

SPP11 concentrates from the outset on the strategic role and importance of open space in the wider policy and legislative context of the Land Reform Act (2003) and the Scottish Executive’s agenda for health improvement and increased physical activity.  Recognition is given to the difference challenges, opportunities and needs in rural as opposed to urban areas.

Wales

TAN 16 looks at the contributions planning policies for sport, recreation and open space can make to economic development, the conservation of Wales’ natural assets and the health, well-being and quality of life of individuals and communities.  TAN 16 makes strong reference to the needs of young people and the significance of children’s development through play.

Fields in Trust Comment

The starting points for the three documents is different as can be seen here. England stresses the social thinking in the background; Scotland stresses, justifiably, its health agenda; we are pleased to see the emphasis on the importance of children’s development coming from Wales.

The Approach to Standards

England

PPG17 relies exclusively on local standards

Scotland

SPP11 introduces minimum standards for open space in new developments for the first time varying the standards according to the type of development

Wales

TAN 16 calls for locally generated standards, though it clearly recognises the helpful contribution that the NPFA’s Six Acre Standard can make to local planning authorities formulating their own standards of provision

Fields in Trust Comment

There is common recognition of an over-reliance on national standards historically.  
The NPFA is currently out to consultation on the six Acre Standard but early indications are that throughout the United Kingdom the standard remains a useful starting point and provides for the possibility of benchmarking between similar local authorities.  In contrast to central Government policy in England, local planning authorities often make use of the recommendations and this merits recognition when a new PPS is produced in England.

Common Approaches

There is support across the three nations for an approach which includes identifying local needs through local audits and assessments, followed by the determination of local standards which will form policies in development frameworks or plans.  There is also clear recognition that undoubtedly historical standards adopted by local authorities have tended to concentrate on quantity to the exclusion of quality and accessibility

Scotland

No time frame is stipulated for the preparation of open space Audits. It is recommended that audits should be updated every five years

Fields in Trust Comment

Quality & Accessibility are now allocated priority over quality though it is cautionary to underline that there can be no quality or accessibility without quantity. This is particularly important at the local level. We recommend a stipulated end date by which audits should be prepared.
We welcome recommendation in SP111 to update every five years and consider it should also be applied elsewhere as otherwise they can quickly be out of date.

Protection of Playing Fields

There exists a clear presumption against the development of playing fields in all three documents.  There are exceptions to the rule which are generally recognised such as developments providing ancillary use, proven excess of supply over demand calculated in the long term and development accompanied by acceptable replacement facilities

England

Sport England developed a policy of allowing development on the basis of a benefit to sport

Fields in Trust Comment

We consider that Sport England’s policy has resulted in an unbalanced reinvestment of proceeds into indoor rather than outdoor facilities.  Unfortunately, the Government was persuaded to incorporate this exception into PPG17.  This has worked to the detriment of open space generally and the Government’s wider health agenda.

Miscellaneous

England

Playing field defined as area containing one or more playing pitches which are delineated and used for specified sports

Scotland

Playing field is defined as a sports pitch of 0.4 hectares or more.Protection also accorded to smaller sites that can be used for specified sports

Wales

Playing fields defined as in England

Fields in Trust Comment

We welcome the move in Scotland to protect smaller sports sites and recommend that it embraces wider spectrum of sports. We recommend that England and Wales adopt this approach.

Conclusion

The planning system does not stand alone.  The use and public access to safeguarded facilities can be strengthened by other legislation such as exists for school playing fields in England.   Similar legislation is needed elsewhere I the UK and parallel legislation is needed for community playing fields in the ownership of local authorities.
Planning for open space, sport and recreation has gone up the agenda significantly over the last two decades.  The loss of valuable open spaces and playing fields has reduced though more could be done through very simple measures.  SPP11 and TAN16 are more fit-for-purpose for planning in the 21st century, but that is in part due to the fact that things have moved on considerably in the 4 years since PPG 17 was first published.  A review of PPG17 is urgently needed, and much can be learned from Scotland and Wales.

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