PFM 5 - Fields in Trust

Dear Sir/Madam

Fields in Trust (FIT), the new operating name of the National Playing Fields Association, is a registered charity concerned with improving the quality of life and health of all members of society, by assisting in the provision, improvement and protection of high quality, well used facilities for outdoor sport, play and recreation.

FIT has assisted Dai Lloyd AM with the preparation of the measure and is listed as a proposed consultee on playing field disposals.  Below are the questions to the questions listed in Annex 2 of the Consultation Paper.

FIT agrees with the principle of the proposed measure because it will ensure a more thorough examination of the playing field’s value to the local community and its impact if lost.  This will make for a better informed decision on whether or not to proceed with disposal.  If it is found to be an important facility, it will discourage disposal or encourage efforts to secure a suitable replacement.  This will mean that the benefits provided by the playing field will not be lost.

FIT agrees with the definitions overall but has some comments regarding the ‘playing pitch’ definition:

Under point 2(d)(i) could athletcs be included?

Netball is listed as using an area 0.2 hectares or more.  A netball court is actually 0.05 – 0.07 hectares (and basketball is 0.06 hectares).  Could an additional point be inlcuded as follows ‘(iv) is 0.05 hectares or more in area and is used for the use of playing netball or basketball’

FIT is pleased that under 3(1)(a) there must be consideration to the provision, quality and accessibility of playing fields in the locality.  FIT however would also like to see reference to the demand for playing fields.  Knowing the level of provision is only half the story as it must be compared against demand to see whether there are sufficient facilities.  Provision should be able to meet and, in case of a possible future increase, preferably exceed demand.  If it is not possible to determine demand, reference could be made to FIT’s well established and recognised standards on playing space provision.  Authorities should not proceed with disposal if provision does not meet demand or recognised standards.

FIT asks that there is clearer direction on what constitutes ‘reasonable steps’ to bring the impact statement to attention.  FIT recommends that letters are sent to the consultees. Other than that, FIT believes the provisions regarding consultation are appropriate.

FIT is happy that the consultees listed are appropriate but suggests that the governing bodies of the particular sports affected could also be notified.

FIT believes that the requirements placed on the local authority having decided to proceed with disposal are satisfactory.  In particular, the preparation of a ‘decision statement’ is welcomed as it will provide justification for the disposal that is available for scrutiny.  This will ensure there has been proper consideration to relevant legislation including this measure and planning policy.

FIT supports the powers of the Welsh Ministers to issue directions to local authorities because it will ensure full compliance with the measure.  Past experience of the Town and Country Planning (General Development Procedure) Order 1995 which requires planning authorities to consult the Sports Council for Wales on applications affecting playing fields has shown that on occasion, authorities have failed to consult and probably because there is no penalty.  Directions will help to address this problem.

FIT will incur costs as a result of this proposal mainly through the staff time spent on reviewing and commenting on proposed playing field disposals.  FIT estimates half a day a week will be spent on this work and this eqautes to roughly £5,300 per annum.    

FIT is happy for its name along with the above comments to be published and available for public scrutiny and discussed at future committee meetings.  FIT is prepared to give oral evidence to Committee if required.

Yours sincerely,

Rhodri Edwards
Rheolwr Datblygu/Development Manager
Meysydd Chwarae Cymru/FIT Cymru