Playing field designation and the sport consultation
A playing field is the whole site containing at least one pitch. Here is how the statutory consultation works, which exception to rely on and how replacement is secured.
Development on or next to a playing field triggers a statutory consultation with the national sports body, and that consultation is the single most predictable cause of delay on school, church and recreation ground sites. The definition in the procedure order is wider than most applicants expect: a playing field is the whole site that contains at least one playing pitch, so car parks, verges and scrub inside the site boundary fall within it. Getting the playing field consultation right means knowing which of the published policy exceptions you are relying on before you submit, not after the objection arrives.
An objection from the sports consultee is not fatal. But it changes who decides the application, and it can remove the authority's power to grant permission on its own.
What counts as playing field land
The Town and Country Planning (Development Management Procedure) (England) Order 2015 defines a playing field as the whole of a site that encompasses at least one playing pitch, and a playing pitch as a delineated area which, together with any run-off, is of 0.2 hectares or more and is used for one of a listed set of sports. Association football, rugby, cricket, hockey, lacrosse, rounders and several others appear on that list.
Three consequences follow from the wording.
The site is the unit, not the pitch. A development on a corner of a recreation ground 80 metres from the nearest goalmouth is still development on a playing field.
The 0.2 hectare threshold applies to the pitch, and smaller delineated areas such as a five-a-side court or a tennis court do not create a playing field on their own. Land that has lain unused for years can still qualify, because the test looks at use rather than current condition, and a pitch mothballed during a school rebuild remains a pitch.
Check the designation on the policies map as well as the physical evidence, and if the map and the ground disagree, our note on errors on a policies map and how to deal with them sets out the usual route.
When the statutory consultee must be consulted
Consultation is required where development is likely to affect land used as a playing field, and the requirement is set out in the procedure order rather than left to local discretion. In practice the trigger catches playing fields owned by local authorities, land used by educational institutions, and sites laid out as pitches for the listed sports.
The consultee will also comment where it has not been formally consulted, so a pre-application approach is worth making even where the trigger is arguable. Officers will often tell you at that stage which exception they expect you to rely on, which saves a wasted submission.
Where a church hall, scout hut or village institute sits on part of a recreation ground, applicants frequently assume the playing field rules do not apply because the building footprint is small. They do apply. The question is which exception fits.
The policy exceptions that allow development
The published playing fields policy works on a presumption against development, with five numbered exceptions. The current version should be checked on the consultee's own website, because the policy has been revised, but the substance of the exceptions has been stable.
| Exception | Substance |
|---|---|
| E1 | The development does not affect the quantity or quality of pitches, or their use |
| E2 | It affects only land incapable of forming part of a playing pitch |
| E3 | The lost playing field is replaced by provision of equivalent or better quality and equivalent or greater quantity, in a suitable location, with equivalent or better management, before the development starts |
| E4 | The development is for a sports facility whose benefit to sport outweighs the loss |
| E5 | The area lost is no larger than needed to build a new or replacement sports facility and its ancillary works |
Pick one and build the case around it. An application that gestures at several at once reads as an application that satisfies none, and the consultee's response will say so.
E2 is the exception most often claimed and most often misapplied. Land incapable of forming part of a pitch means land that physically cannot be used that way, not land that happens to be a muddy strip at the edge. Gradient, trees, permanent structures and width are the arguments that work.
Playing pitch strategies as evidence
Most authorities hold a playing pitch strategy prepared to the national guidance on assessing needs and opportunities. It is the document that tells you whether the authority's own evidence base says there is a surplus or a shortfall of each pitch type in your area.
Read it before you design the scheme. A strategy showing a shortfall of adult football pitches in the sub-area will make an E1 or E2 case harder and an E3 replacement case more expensive, because the replacement standard has to match the identified need.
National policy protects existing open space, sports and recreational land unless an assessment shows it is surplus to requirements, the loss would be replaced by equivalent or better provision, or the development is for alternative sports provision whose benefits clearly outweigh the loss. Where the authority's own strategy is more than a few years old, expect to be asked to update the relevant part of it. That evidence also underpins the wider Open Space Assessment submitted with larger schemes.
Replacement provision and its standard
Replacement is judged on quantity, quality, location and management, and all four have to be addressed.
Quantity is measured in pitches of a given type and size rather than in hectares, because two hectares of land that cannot accommodate a full-size adult pitch does not replace one. Quality means a constructed pitch built and drained to the recognised performance standard for the sport, not a mown field. Location means accessible to the same community of users, which is usually tested by travel distance and public transport. Management means a body able to maintain the pitch and a community use arrangement giving the displaced clubs secure access.
Build the cost of all four into the appraisal early. Natural turf pitch construction with drainage, a changing facility and a car park is a substantial capital item, and a scheme that discovers it at viability stage tends to come back with a worse offer that the consultee then rejects.
Securing replacement through an obligation
Replacement is secured by a planning obligation under section 106 of the Town and Country Planning Act 1990, and sometimes reinforced by a condition preventing development until the replacement is available.
The drafting points that matter are the trigger, the specification, the management arrangement and the long stop. Replacement before loss is the usual expectation under E3, which means the obligation has to prevent commencement, or at least prevent loss of the existing pitch, until the new one is built, drained, established and playable. A pitch handed over in October and unplayable until the following autumn has not replaced anything for a season.
Include the maintenance period and the community use agreement in the obligation itself. Leaving them to a later agreement between the club and the landowner is how replacement provision quietly degrades. Where the land involved is common land or a town or village green, a different and stricter regime applies on top, as set out in common land and village greens as development constraints.
Resolving a holding objection
Objections are usually framed as a sustained objection or as an objection capable of being withdrawn if specified matters are resolved. Read which one you have.
Where the objection is capable of withdrawal, the route is a technical dialogue: pitch layout drawings, a drainage design, a construction specification, a management plan and draft obligation wording. Three rounds of that is normal and each round takes weeks, so build it into the programme rather than the determination period.
Where the objection is sustained and the authority is nonetheless minded to approve, the consultation direction requires the application to be referred to the Secretary of State before permission is issued, which adds months and introduces the possibility of a call-in. Check the current direction, because it has been reissued. That referral risk is the real reason to resolve the objection rather than to argue the planning balance at committee.
If your site also includes children's play provision, the standards for that are assessed separately through a Play Space Assessment and should not be confused with pitch provision.
This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it.
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Frequently asked questions
What is the legal definition of a playing field?
The Development Management Procedure Order 2015 defines it as the whole of a site encompassing at least one playing pitch. A playing pitch is a delineated area which, with any run-off, is 0.2 hectares or more and is used for one of a listed set of sports. The whole site counts, rather than the marked pitch alone.
Does a disused pitch still count?
Often yes. The test looks at use as a playing pitch rather than present condition, so a field mothballed during a school rebuild or left unmown for a few seasons can still fall within the definition. Argue the point with evidence of how long the use ceased and why, rather than assuming disuse removes the designation.
Which policy exception should an application rely on?
One, chosen before submission. The published policy has five numbered exceptions covering no effect on pitches, land incapable of forming a pitch, equivalent or better replacement, a sports facility whose benefits outweigh the loss, and an area no larger than needed for a replacement facility. Applications claiming several at once tend to satisfy none.
What standard must replacement provision meet?
Equivalent or better on quantity, quality, location and management. Quantity is measured in usable pitches of a given type, quality means construction and drainage to the recognised performance standard for the sport, location means accessible to the same users, and management means a body capable of maintaining it with secure community access.
What happens if the consultee objects and the council still wants to approve?
The consultation direction requires the authority to refer the application to the Secretary of State before issuing permission where it proposes to grant against a sustained objection. That adds months and introduces the possibility of a call-in, which is why resolving the objection technically is usually faster than arguing the balance at committee.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.