Memorandum by Business in Sport and Leisure
Limited (BISL) (PPG 08)
1.1 Business In Sport and Leisure (BISL)
is an umbrella organisation which represents over 100 private
sector companies in the sport and leisure industry. Its members
include most of the major operators of commercial sport and leisure
in the UK and many consultants who specialise in this field. Members
of BISL who are listed on the London Stock Exchange have a combined
market capitalisation in excess of £40 billion. Activities
range from operators of health and fitness clubs to those involved
in sport tourism, running local authority leisure facilities under
PPP arrangements and professional rugby clubs plus a wide range
of consultants in these fields. A full list can be found on our
1.2 BISL has working groups on both Property/Planning
and Sport comprising experts and representatives of senior management
from our member companies in those fields, and BISL has long had
an interest in land-use planning issues. We have published and
revised our booklet "A Guide to Site Criteria for Commercial
Leisure" which looks at 19 different types of facilities,
including an indoor tennis, sport and leisure club; private members
health and fitness clubs; hotels with leisure facilities; multi-purpose
small stadia; and stadium complexes. We also responded to the
Government's recent consultation on the revision of PPG 17.
1.3 BISL would welcome the opportunity to
give oral evidence to the Committee on behalf of the private sector
sport and leisure industry on the specific areas listed in the
summary at the end of this submission.
2.1 Sport is a cornerstone of the Government's
policies towards education, health and law and order. Many benefits
are spelt out in BISL's submission on the draft PPG 17, but without
facilities many sports cannot take place. In putting forward a
revision to PPG 17, DTLR should be reflecting central Government
policy and ensuring that local planning authorities understand
the vital importance of planning for sport. Nothing in the revision
presented thus far does anything to encourage any person or body
to think that sport is important.
2.2 BISL believes that it is absolutely
vital that PPG 17 sets the national context for sport. It should
encourage local authorities to identify sites and policies which
ensure that facilities for sport are refurbished and built afresh.
Sport England estimates that £3.2 billion is required to
update sports facilities in England to bring them up to the standards
required by a discerning public. This will inevitably mean use
of the private sector to provide investment (see case studies
below) through schemes such as Best Value, Public Private Partnerships
or via planning gain. The draft PPG must take account of the modern
mechanisms by which facilities are provided, and provide guidance
on how the planning system can assist in the securing of investment
in these facilities. Currently, it appears intent on making things
more difficult for the sports operator.
2.3 Sport has seldom been at the top of
the agenda for local authority planners and this revision does
nothing to encourage a change in this culture for land-use planning.
We would like to see local authorities have a statutory responsibility
to plan for and provide or allow others to provide sporting facilities
of a quality and type to suit their catchment areas. This should
include the need for "additional" sports and leisure
facilities. The draft PPG refers to a need for such provision,
but does not specifically state a need for the allocation of sites
in Development Plans.
2.4 Turning to the specific terms of reference
for this inquiry, we would like to comment as follows:
REVISED PPG TO
3.1 The Committee has expressed a particular
interest in the contribution of the draft PPG 17 to strategic
planning for sport. BISL would like to discuss the following issues
with the Committee:
3.2 Strategic planning for sport is vital
at a regional and local level, in Regional Development Plans,
Local Development Plans and Unitary Development Plans. The revised
PPG 17 does not do enough to encourage the planners responsible
for these plans, or to see planning for sport as a priority. The
PPG should provide guidance on how Local Planning Authorities
should take a strategic approach to sports provision within their
area. Reference should be made to the Sport England publication
"Planning Across Boundaries". It is now widely accepted
that participation in sport can contribute to the health of the
nation, to improved standards in education and to an enhanced
lifestyle for people in deprived communities and those who are
socially excluded. The provision of good, modern, well-designed
and well-located sports facilities is vital to the local community.
The revised PPG should go much further in supporting the policies
and programmes promoted by the Department of Health, Home Office
and by DCMS. There is a real need for joining up these key threads
within the revised PPG 17.
3.3 Annex 1 contains three case studies
demonstrating ways in which sporting facilities are provided by
the commercial sector. We believe that these are in tune with
the aims of the Urban White Paper, both in terms of attracting
investment and improving sports provision, with the associated
benefits that these bring to communities. We would like to see
the draft PPG 17 amended in order to encourage more schemes of
PPG TO THE
4.1 In this section, we would particularly
like to comment on the location of sports facilities and the underlying
economic factors which influence the provision of sporting facilities.
The Location of Sports Facilities
4.2 The draft PPG 17 relies heavily on Government
policies on planning as set out in PPG 6 (Town Centres and Retail)
and PPG 13 (Transport). Both sets of guidance rely rigidly on
the precept that new facilities should be built exclusively in
town centres and be accessible primarily by public transport.
Sport is, however, different for the following reasons:
4.3 Few sites available in town centres
are large enough for sport. Even if they are suitable, they are
almost always too valuable for use by a non-profit making activity,
such as amateur sports clubs.
4.4 PPG 6 in particular encourages people
to live and work in town centres. Many people in the UK do live
in town centres, but equally many people live outside the town
centre in residential suburbs or rural areas. Sports facilities
must cater for everyone and participation in sport must be encouraged
from a young age if children are going to adopt healthy lifestyles
for the future. Sports facilities should be near to home, preferably
available on foot or be adjacent to schools. The New Opportunities
Fund has £750 million available over the next three years
to fund new and refurbish existing sports facilities and most
of the funding will be available for capital grants. The new guidance
makes no mention of this significant capital allocation or any
comment on the significant new funding which the National Lottery
has introduced for sport over the past six years. The availability
of this funding has key implications for planning policy for sport
and the draft PPG should give clear guidance. Furthermore, sport
operators will find it difficult or impossible to afford the prices
of sites in town centres, particularly those identified for A3
or A1 use.
4.5 There seems to be little mention of
sports facilities in rural areas where public transport is often
unavailable. In rural areas it may make more sense to place sports
facilities on the edge of town centres so that users from the
surrounding villages do not have to take their cars into the town
centre. This can often increase their journey time ten fold. This
was recognised in recent DETR research on "Planning for Leisure
and Tourism" (March 2001).
4.6 There is a need for a greater understanding
of different types of sports facilities. Health clubs are suitable
for many different locations to cater for office workers, and
with easy access for use from home. Indoor tennis facilities need
large sites, are most unlikely to be situated in town centres
and may well be suited for sites adjacent to open space. Multi
sports pitches are often only viable if they are flood-lit. They
have to be located in areas where they will not cause undue nuisance
to local residents.
4.7 The Urban White Paper and Lord Foster's
Urban Task Force Report looks at establishing sustainable communities
where facilities are available to "neighbourhoods".
This means that sports facilities should be part of planning in
suburbs and in new towns. There is little evidence that this approach
is appreciated in the draft PPG 17.
To summarise the section, the main points to
The location of various types of
sporting facilities will depend on the nature of the facility;
size/noise/floodlighting/attendees, rather than an automatic assumption
that all new developments should be located in town centres.
Consideration should be given to
the visitors to sporting facilities when deciding on the location
of new sports facilities. It will often be more appropriate for
new developments to be located in residential areas to reduce
the need for people to travel into town centres.
Rather than looking at the sequential
approach to site selection, travel patterns should have more priority,
whereby consideration is given to sites which are most accessible
by a variety of modes of transport for the population.
4.8 The draft PPG makes it clear that decisions
on the location of sports facilities should be taken on planning
grounds alone and that economic factors have little bearing on
the decision making process. This ignores the fact that sport
is rarely an economic activity and if the private sector is to
be encouraged to invest in sport, then the sites available have
to be sustainable. Sport and leisure facilities can be both commercial
and non-commercial facilities. Each type of facility has its advantages
for the community and needs recognition.
4.9 Most sports facilities provided by the
private sector have to include changing rooms, administrative
accommodation and social facilities. Sport is no longer just about
participating and moving on. Sports centres are seen as places
for social activity, somewhere to meet and relax. The lifestyle
and essential ingredient of quality in new and refurbished sports
facilities which will encourage people to use them must be allowed
for and encouraged by planning authorities. There seems little
mention of this in the revised draft.
4.10 It should be noted that one of the
Key Measures within the Urban White Paper is the need for incentives
to boost private investment, as is the need to promote culture,
leisure and sporting activity. New Sports facilities can provide
a focus for regeneration; bringing both people and investment
into previously run down areas.
PPG IS SUCCESSFUL
5.1 BISL welcomes the inclusion of open
spaces in the draft PPG. However, we do feel that the balance
has tipped too much in this direction at the expense of sport
provision. Furthermore, we would like to see a definition of open
space, as it is not clear for planners whether proximity to parkland
or countryside and accessibility of designated areas should be
taken into account when deciding what open space is appropriate
for a community.
5.2 Similarly, clearer definition of sport
is needed in the PPG, which at present is confusing and inconsistent.
It would also be helpful if guidance can be given about the priority
for a developer providing planning gain by means of open space
over other demands like transport improvements. The DTLR guidance
"Better Places to Live by design: a companion to PPG 3"
recognises that contributions towards school places, improving
public transport, libraries, community halls, medical facilities
and affordable housing are also considered important and there
is a need for these issues to be balanced and prioritised. This
should also apply to open space and guidance given in the draft
6.1 The Urban White Paper "Our Towns
and Cities" published in November 2000 promised new planning
policy guidance to put urban renaissance at the heart of the urban
planning system. It also promised to improve the quality of parks,
play areas and open spaces. The provision of good, accessible
sport and leisure facilities must be part of this promise.
6.2 Sport is not a statutory provision for
local authorities. Funding for sport is discretionary and has
for many years been declining, both in the capital funding to
refurbish existing community facilities and revenue support to
maintain these facilities. As referred to in paragraph 2.2 above,
Sport England estimate that £3.2 billion is required to update
sports facilities in England to bring them up to the standards
required by a discerning public. Since Compulsory, Competitive
Tendering was introduced in 1989 for sport, the private sector
has been investing capital and revenue in return for management
contracts for local authority facilities.
6.3 Business In Sport and Leisure has put
together examples of investment from £200,000 to £5
million and has shown that private sector expertise in participating
in Best Value contracts and through Public/private partnerships
has considerably enhanced both the quality and services offered
in sports centres in urban and rural locations. Earlier this year,
BISL ran a joint seminar with the Local Government Association
on this subject for local councillors and council officials.
6.4 The draft PPG 17 makes no mention of
the Urban White Paper, nor suggests changes to the way in which
planning policies will work in our towns and cities to ensure
that people have access to and are encouraged to participate in
7.1 Whilst this inquiry focuses on the relationship
between the draft PPG 17 and the Urban White Paper, we suggest
that the Committee may also like to consider what synergies exist
between the draft PPG 17 and the Government's Plan for Sport,
particularly with respect to the mechanisms for delivering investment
in new facilities.
7.2 It is clear that much of Government
spending will be directed towards facilities in schools under
the Space for Sport and Arts scheme. School facilities are usually
generally accessible to communities and are, on the whole, underused.
The Committee may wish to consider mechanisms for opening up school
sports facilities for wider community use.
8.1 BISL would like to discuss the following
issues with the Committee:
That the draft PPG 17 is too rigid
in its application of planning policies in PPG 6 and 13 in that
sport and its characteristics are different from retail and other
economic activity better suited to town centres.
That private sector companies need
to be encouraged to invest in the building of sports facilities
and in their running costs in order for local authorities to make
good the £3.2 billion investment required to upgrade existing
facilities. The revision of PPG 17 should acknowledge this.
Such encouragement needs planning
policies which take account of the economic and regeneration issues
and PPG 17 needs amending to this effect.
That the draft PPG 17 does not pay
enough attention to the Urban White Paper in looking at innovative
ways of ensuring that sports facilities are included with new
housing developments and in areas of deprivation.
Finally, that the draft PPG 17 does
not consider the wider aims of the Urban White Paper in improving
the health and education of communities and reducing crime, and
the contribution sport can make in this area.