Consultation on the Draft National Planning Policy Framework (NPPF) is now closed. However, since the Government published its proposed reforms to the planning system in July 2011, more concerns and questions appear to have been raised than answers provided.

A primary issue for those involved in sports and recreational provision is the perceived move towards the ‘easing' of protection currently given to playing fields. Interested parties such as the Sport and Recreation Alliance (SRA) and Sport England highlight concern that in their current shape the proposed reforms will weaken the ability to protect playing fields from development proposals. This could in turn lead to future loss of this type of provision across the country.

The concerns stem from one of the Draft NPPF's more contentious changes; to a presumption in favour of sustainable development. Whilst this is, in theory, an extension of the present presumption in favour of a development that is in line with a development plan; there are flaws and it is these that underpin the concerns expressed. Most noticeably there is a strong focus (highlighted throughout the NPPF) on the need to support sustainable economic growth. It goes without saying that economic growth should be a key driver, however, the way in which the legislation is presently framed is likely lead to confusion with regard to and the overlapping use of the terms ‘sustainable development' and ‘sustainable economic growth'.

Sustainable development, according to the widely acknowledged Brundtland definition is; development that meets the needs of the present without compromising the ability of future generations to meet their own needs. Sustainable economic growth refers to economic growth that can be sustained. The two are clearly related but very different in implementation.

Furthermore, the ambiguous language used in the NPPF contributes to concerns that the economic benefit of new developments will outweigh those associated with provision of sport and the retention of sporting facilities. The SRA argues that as most sporting facilities are subsidised or non-profit making it is easier to prove an economic case in favour of a development located on a grass field. This ties-in with concern of organisations like the RTPI about the emphasis on a case-by-case decision making process, rather than a plan-led system (i.e. assessment of a proposal against the alternatives available).

The Government argues that open spaces and playing fields will benefit from new protection powers under the reforms such as that of communities being able to designate open space provision as ‘Local Green Space' which cannot be developed upon. In order for a site to be awarded this designation it will need to be identified as being of local significance for its visual, historic, recreational and/or wildlife value.
It will be interesting to see whether (and the extent to which) these new powers and the subsequently revised NPPF answer and clarify the concerns expressed by interested parties to date.