Royal Commission on Environmental Pollution

The Central Council of Physical Recreation (CCPR), as the national association for the governing bodies of sport and recreation, welcomes the opportunity to respond to the consultation. On behalf of the 270 member sports bodies, we have long campaigned to protect playing fields and green spaces from development. The CCPR's experience is that more could be done to improve cross-departmental strategies. In addition, the pressures of devolution have resulted in differing planning arrangements for the home countries. These do not assist the production of consistent environmental guidelines for the United Kingdom.

Without wishing to comment in depth on the issues raised in your letter, we would like to take this opportunity to place our concerns on record about the protection offered to green spaces and playing fields by the planning system.

1.     Right of Appeal
There are serious reservations about the unfairness of a planning system that allows developers to appeal when an application to build on green space is refused, but allows no similar rights to local people when an application is accepted.

It is vitally important that local voluntary groups do not face financial ruin as a result of an unsuccessful appeal. Serious consideration should be given to capping the maximum costs at a level of around £500. It is recognised that there is a need for financial disincentives to prevent spurious appeals.

2.     Potential Conflicts of Interest
There are reservations about the system that appears to place local authorities in a position to determine planning applications affecting council owned land. One example of this is school playing fields, where any decision will have a significant impact upon the local authority's education budget.

This potential conflict of interest serves to undermine the confidence of local residents in the fairness of the planning system.

3.     Proper Consultation versus Streamlining the Planning Process
Most local residents will be less organised than professional developers. Local resident organisations are generally run by volunteers in their spare time. As such, any moves to speed up the planning process must ensure that voluntary groups are not excluded by reducing the time available for consultation and responses.

The CCPR would support moves to increase consultation times and give adequate weighting to voluntary groups' submissions.

In conclusion, it is the CCPR's opinion that the above reasons mean that the current planning system is in need of significant improvements in order to give adequate weighting to environmental considerations.

I trust that you find the above observations helpful and thank you once again for the opportunity to place the CCPR's concerns before the Commission.

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