National Assembly for Wales

PFM 4 - Councillor Lisa Mytton

Dear Mr Lloyd,

Re: -

Consultation – Proposals for Proposed Playing Fields (Community Involvement in Disposal Decisions) Measure

With reference to the above I wish to submit the following responses as an Independent Councillor for the Vaynor Ward, Merthyr Tydfil County Borough Council and additionally as an active member and on behalf of the Vaynor Community forum, a residents association.

I wish to advise you that a large amount of my manifesto concentrated on saving a playing field in my ward, we have been fighting to retain this area of open space – playing field for five years.  As a residents group we have been lobbying our council to ensure it is not redeveloped, this matter is ongoing and has been carried out with the support of ‘Fields in Trust’.

In response to the consultation paper I would welcome the opportunity to give an oral response to a future committee.

1. The Proposed Playing Fields (Community Involvement in Disposal Decisions)(Wales) Measure, requires Local Authorities to consult with the local community before disposing of playing fields. The overall aim is to ensure that proper consideration is given to a proposed disposal and its impact on the health and wellbeing of the local community, before it proceeds.

Do you agree with the principle of the Proposed Measure? Please give reasons for your view and what impact you consider that the proposals will have.

I fully agree with the principle, the previous administration in M.T.C.B.C were not open or transparent and had a history of poor communication with general public. This would impact positively because if the measure is successful the community and local residents groups like our own VCF would have a voice, far too often decisions are made without proper consultation.

2. Section 2 of the proposed Measure provides definitions of “dispose”, “local authority”, “playing field” and “playing pitch”. In particular, the definitions of “playing field” and “playing pitch” are defined in terms of area and certain sporting activities.

Do you agree with the principal definitions used in section 2 of the Proposed Measure? If not, please explain why and provide any alternative suggestions.

I agree with the definitions used, I’m particularly pleased to see the term ‘playing field’ includes organised sport or walking and play, it is imperative that we include the less formal use of these areas.

3. Section 3 of the proposed Measure requires Local Authorities to produce an impact statement that identifies the nature of the proposed disposal and describes its impact on the overall provision of playing fields in the locality; the health and wellbeing of the local residents and the local Health and Well-being Strategy. The impact statement must be available for inspection for a four week period and notices must be placed in the local press.

Do you agree with the proposed contents of the impact statements? Please provide an explanation for your views.

I agree, not all residents are part of a local association by ensuring the local authority have to take measures to post the impact statements within the locality, local press and website makes it far more accessible to the wider audience and  opportunity for further consultation.

4. Under the consultation provisions set out in section 4, Local Authorities must take reasonable steps to draw the impact statement to the attention of the statutory consultees listed in the proposed Measure and any other groups that may make use of the fields. They must then consider any representations made (section 5).

Are the provisions regarding consultation appropriate? Please explain your viewpoint.

Yes they are appropriate again because they are engaging the wider audience in the case of our playing field, only half is used by a local sporting association the rest is used by local residents for leisure, walking and playing therefore the opportunity for discussion is widened and all can submit their views.

5. Statutory consultees are listed in the Schedule to the proposed Measure.

Are the consultees listed in the Schedule appropriate? Should less specific consultees be identified? If so, how should consultees be identified?

Yes very appropriate it ensures that the whole community and its diverseness are covered i.e. from the Sports Council for Wales through to Age Concern.

6. Section 6 sets out the action that Local Authority must take once it has decided to proceed the proposed disposal.

Where the authority has decided to proceed with a disposal of Playing Fields after a consultation, do you think the requirements placed on a Local Authority are satisfactory? Please explain your view.

Yes, it’s fully explains their responsibilities and ensures that if a local authority decides to proceed the process is open and transparent; this also supports more effective communication with all those involved.

7. Section 7 allows Welsh Ministers to issue a direction suspending a disposal following representations in order to determine whether the process in the Measure has been complied with. If it has not they may issue a direction requiring the Local Authority to comply.

Please outline your views on the powers of Welsh Ministers to issue directions to Local Authorities.

I firmly believe that any local authority decision should be fully scrutinised and therefore back Welsh ministers to have the ministerial authority to issue a direction to comply.

8. Will the proposals result in your organisation incurring financial costs? If so, what will they be (please quantify)?

For the residential group the only financial costs would be in holding public meetings and sending out literature in order to communicate and consult with the residents affected by any local authority proposal, Cost Implications would amount to no more than £500. However for a residents association and or sporting association to seek leasing of the land from a local authority etc in order to maintain it for recreation then further funding opportunities would need to be sought.

I trust the above is all in order, and welcome any opportunity to discuss the issues and history of our fight to retain playing fields.

Yours Faithfully,

Lisa Mytton

Cllr Lisa Mytton