The Government recently confirmed that Sport England’s role as a planning consultee is going to be reduced to a smaller remit, following long-standing speculation that it would lose its position entirely. In light of the news, Tom Molyneux-Wright spoke to Campus Estate Management Magazine about what the change means for the future of education planning applications.
It had been muted for some time that Sport England could, along with other consulting bodies, lose its role as a statutory consultee on planning issues, following the Government’s consultation on reforms to the statutory consultee system.
Despite the warning, the Government didn’t go as far as to strip its consultee role. It confirmed that Sport England will retain its statutory role, but with a narrower remit.
The intention is to focus Sport England’s expertise on the most significant proposals affecting playing fields, while removing the need for consultation on a range of lower-risk applications. The Government expects the changes to reduce the number of planning applications requiring Sport England’s input by more than half.
The changes are particularly relevant to public infrastructure projects, especially schools, given that around 60% of Sport England’s current planning consultations relate to education development.
The Government’s decision followed strong resistance to the proposal with 80% who responded during the consultation opposing its removal. Respondents highlighted the importance of Sport England’s specialist expertise in protecting playing fields and expressed concern that local planning authorities may not have the resources or experience to replicate it.
The Government has therefore gone for the middle ground – Sport England will remain a statutory consultee but will be consulted on fewer applications.
The revised approach will focus on significant proposals involving the loss of playing field land, including applications where an existing pitch is greater than 0.4 hectares.
A number of lower-risk categories will no longer require statutory consultation. These include:
- playing pitches below 0.4 hectares;
- development adjacent to playing fields;
- ancillary facilities such as pavilions, parking, lighting and storage;
- “behind the wire” defence and prison sites; and
- temporary classrooms and other routine school development.
The Government expects this to allow Sport England to concentrate its resources on proposals where its expertise is most likely to add value.
Importantly, the changes do not mean that playing fields outside these categories will no longer be protected. Planning policies and other controls will continue to apply, and local planning authorities will still need to consider the impact of development on playing field provision.
Even though the Government has confirmed its intention to narrow Sport England’s statutory consultation role, the changes require amendments to the relevant regulations – which will follow in due course. Therefore, until those regulations come into force, the existing statutory consultation requirements remain.
So, the status quo will remain, with Sport England being consulted until those revised regulations are put in place.
However, the position is different in relation to the revised National Planning Policy Framework (NPPF), which took effect on 17 August 2026.
New Policy HC7 deals with development affecting existing open space, sports and recreational buildings and land, including playing fields, formal and informal play space and allotments. The policy continues to provide strong protection against the loss of these assets, but, it introduces an important additional exception for public service infrastructure.
For most development, loss of existing recreational land will generally only be acceptable where replacement provision is equivalent or better in terms of both quantity and quality. For public service infrastructure, however, HC7 allows the resulting loss to be replaced by equivalent or better provision in terms of quantity and/or quality.
This is potentially significant for projects such as schools and healthcare facilities. Public service infrastructure is defined in the NPPF as including education and healthcare facilities, as well as facilities for blue-light services, social care, libraries and criminal justice uses.
The use of “and/or” offers greater flexibility than the previous wording. It allows a qualitative improvement to the remaining sporting provision to be used to justify a quantitative loss.
That does not mean that public infrastructure schemes can simply trade playing field land for better facilities. The policy still requires the loss to be properly addressed, and the planning values of each proposal will need to be considered on its facts.
The reason DPP is highlighting this is that it’s particularly relevant to education projects.
Sport England’s Playing Fields Policy (which was last updated in 2021) takes a relatively protective approach to the loss of playing field land – i.e. Sport England will generally object unless one of its policy exceptions is satisfied.
These exceptions mostly cover situations where there is surplus playing field provision; development involves additional facilities without adversely affecting pitches; affected land is incapable of forming part of a pitch; equivalent or better replacement provision is provided; or a new sports facility provides benefits which outweigh the detriment from the loss.
Where Sport England maintains an objection and the local planning authority is nevertheless minded to approve the application, the statutory process can result in the application being referred to the Secretary of State. This can add more uncertainty and delay a project.
The proposed reforms should ultimately remove this extra procedural step from a range of routine, lower-risk developments. This will be particularly helpful for schools looking to build temporary accommodation projects and other development that falls outside the new consultation thresholds.
For larger schemes affecting significant areas of playing field, however, Sport England’s involvement will remain important.
So, what can applicants do, you may ask? Well, the practical approach remains broadly unchanged.
First, applicants should be careful not to treat the proposed consultation reforms as though they are already in force. As we mentioned, until the regulations are changed, the existing statutory requirements still apply.
Secondly, where playing field land is affected, applicants should demonstrate that the loss has been minimised as far as reasonably possible and explain why the land is required to deliver the proposed development.
Thirdly, applicants should look beyond the area of land being lost and consider the quality, usability and accessibility of the sporting provision that remains.
This is particularly important for public service infrastructure projects following the introduction of HC7. For example, a school extension involving a modest loss of playing field land may be better placed to demonstrate compliance where the scheme also delivers meaningful improvements to the quality, drainage, accessibility or usability of the remaining sports provision.
We also advise early engagement with Sport England for significant schemes, particularly while the current statutory consultation requirements remain in force, albeit their pre-application service is currently suspended, making this difficult
Taken together, the reforms point towards a more targeted and proportionate approach rather than a wholesale weakening of playing field protection.
Sport England will retain its statutory role, but its resources will increasingly be focused on the applications where the potential impact on playing fields is greater. At the same time, the revised NPPF provides greater flexibility for public service infrastructure by recognising that improvements in the quality of sporting provision could help offset a residual quantitative loss.
Therefore, if you are planning on making an application like this, there are some simple steps to take – engage early, minimise the loss of playing field land, and show how the overall sporting offer will be maintained or enhanced.
You can read the original article on Campus Estate Management Magazine.
