PF25

Legislation Committee No 1

Response to the consultation on the Proposed Playing Fields (Community Involvement in Disposal Decisions) (Wales) Measure

Community Housing Cymru

1. Is there a need for an Assembly Measure in relation to community involvement in decisions by local authorities whether to dispose of playing fields?

CHC supports the principle of a measure that would ensure full consideration on the future of playing fields.  It is important that there is community involvement in these decisions for reasons of health, wellbeing and social inclusion.  CHC believes that where playing fields are no longer used in a community, a dialogue should take place with local partners and community representatives to examine the possibility of land being used for the benefit of the community in other ways, such as affordable housing.  If this is the case, the design of social housing should reflect the best interests of the local community and environment.  Housing associations in Wales are building to high environmental standards.  As part of the Welsh housing quality standard, Housing associations are building to level 3 of this.  Investing in renewable technology is important thus minimising the impact on the environment.  

CHC believes that housing associations and local partners should work together to examine the suitability of any land for housing and development.  CHC are working with partners such as the National Housing Federation and CECODHAS, the European Network for Social Housing, to influence EU level policies on the sustainability of the housing stock and reducing the environmental cost of new and existing housing.  Our members work with communities, planners and developers to ensure that developments are balanced and provide for all aspects of the community.  Spatial factors are key in considering the impact of housing. The location of housing, access to public transport, employment sites and key services are all vital when considering the impact of housing.  Playing fields also feed into this in terms of the design of communities and what local people want to use the local space for.

2. What are your views on the key provisions set out in the proposed Measure, i.e.

-the duty on local authorities to consider the impact that selling off playing fields would have on local communities before deciding whether to dispose;

-the principal definitions (Section 2);

-the duty on local authorities to prepare and consult on impact statements before deciding whether to dispose (in particular, the method and scale of consultation, and content of impact statements)(Section 3);

-the duty on local authorities to prepare a decision statement, including its content, and the arrangements for making known its decision (Section6);

-the statutory consultees as set out in the Schedule to the proposed Measure; and

- Powers of Welsh Ministers to issue stop and remedial directions to local authorities (Section 7).

CHC believes that it is right that local authorities should assess the impact that reduced provision for sport and recreation can have on their communities and the health and well-being of the people that live in them.  The requirement to send a copy of the impact statement to the occupiers of every household in the locality is important.  The requirement for Welsh Ministers to have powers to intervene in disposal decisions is not neeeded.  Local authorities, as independent statutory bodies, are responsible for ensuring that they comply with the requirements of legislation.

3. What are the practical and financial implications of putting these provisions in place?

4. Will the proposed Measure achieve its overall purpose and aim?

The purpose-"…providing an additional safeguard in the form of a duty on local authorities to assess the impact of the disposal of a playing field on the local community and to consult with certain specified people”, as stated in the document, can be achieved.  Local authorities should consult with local partners.  Disposals should not proceed without a full assessment of the impact.  We support TAN 16 which states that open space has a positive community value for recreation.  We also recognise the view that unused playing fields can represent a significant asset and can help deliver real community benefits under strategic goals in other ways, such as affordable housing.