(TER0053)

Written evidence submitted by the LAWN TENNIS ASSOCIATION (TER0053)

the lta

The LTA is the national governing body for tennis in Britain. As a not-for-profit organisation, our role is to govern and grow tennis in Britain, from grassroots participation through to the professional game.

We work with schools, with volunteers, with coaches and with venues across the whole country. We also represent the interests of over 1,000,000 members, men and women, girls and boys, playing on more than 23,000 courts. 

The LTA runs and supports a network of 11,500 approved tournaments for players of all ages, the four corner-stones of which are the premier grass-court events leading up to The Championships, Wimbledon: the Rothesay Open Nottingham, the Rothesay Classic Birmingham, the cinch Championships (at The Queen’s Club, London) and the Rothesay International Eastbourne. 

The LTA’s vision is to open up tennis and its benefits to more people across the country by making it more relevant, accessible, and welcoming to anyone, from players of all abilities and backgrounds to its millions of fans.

The LTA is a member of the Sport and Recreation Alliance, and we fully support their submission to this Call for Evidence.

summary

1. The LTA supports the intention of the Terrorism (Protection of Premises) Draft Bill and many of the measures contained within it. We are committed to ensuring that our events follow best practice in this area and that we support LTA registered venues and volunteers to do the same.

2. For an accurate assessment of the impact this legislation will have on the sport sector, further clarity is needed in some key areas, including the methodology for calculating capacity, the definition of ‘publicly accessible’ in relation to qualifying premises, the definition of a ‘relevant worker’ and the operation of provisions relating to person(s) responsible for a qualifying premises or event. The role and funding of the regulator, as well as the penalties it can implement, also need further clarification.

3. At the professional level, tennis already operates according to a well-established safety regulatory framework. We write an Event Management Plan for each of our major tournaments - the Rothesay Open Nottingham, the Rothesay Classic Birmingham, the cinch Championships (at The Queen’s Club, London) and the Rothesay International Eastbourne – and hold Safety Advisory Group meetings (SAG) when required. While our major events will qualify for the enhanced tier under Martyn’s Law, as a result of this existing framework, we don’t foresee a significant additional burden to the organisation of our major events.

4. However, at a grassroots tennis level, we have areas of concern and there is a potential for a significant impact and burden on tennis volunteers and organisers. The majority of grassroots tournaments and venues will fall under the standard tier of Martyn’s Law, adding significant additional burden to the volunteers who organise most of these events. Given the low-risk nature of these events, we would support exploration of an exemption for these premises and events.

5. It is vital that there is further consultation with the sport sector to address these concerns and ensure Martyn’s Law is proportionate and implementable, without negatively impacting grassroots sport and its associated health, social and economic benefits.

clarity and consultation

6. For an accurate assessment of the impact this legislation will have on the sport sector, further clarity is needed in some key areas:

• The methodology for calculating capacity – which is essential to understanding the scale and nature of premises which may fall within scope and their specific duties – is not specified and is left to regulations to be made by the Secretary of State.
• The definition of ‘publicly accessible’ in relation to qualifying premises.
• The definition of a ‘relevant worker’ and the operation of provisions relating to person(s) responsible for a qualifying premises or event – which is needed to understand the full impact on grassroots volunteers.

7. We share the Sport and Recreation Alliance’s concerns that the lack of clarity will be exploited by third parties seeking to advise grassroots community sport and recreation organisations on how to comply with their duties under the legislation.

8. Further clarity is needed around the role of the regulator in both the standard tier and enhanced tier of Martyn’s Law. The penalties the regulator imposes must also be proportionate, and, in the case of grassroots community organisations, must take into account the ability to pay. We also believe further details are needed as to how the regulator will be funded. The Bill refers to further regulations specifying how costs will be recovered but we believe there should be more clarity at this point in the Bill’s passage on whether this will involve the levying of fees on those subject to the requirements and, if so, how any such fees would be arrived at.

9. Additional safeguards are needed to ensure appropriate consultation with affected sectors. The Bill should include a clear requirement for Government and the regulator to consult with the sport and recreation sector on the guidance and exercise of the regulator’s functions, prior to publication. The LTA are keen to work with the UK Government to ensure the impact on tennis is considered from grassroots to professional.

Professional tennis and major events

10. At the professional level, tennis already operates according to a well-established safety framework. Each of our major events - the Rothesay Open Nottingham, the Rothesay Classic Birmingham, the cinch Championships (at The Queen’s Club, London) and the Rothesay International Eastbourne – have Event Management Plans and hold Safety Advisory Group meetings (SAG) when required. The same protocols are followed when we play host to the Billie Jean King Cup and Davis Cup, which take place at different venues around Britain. While our major events will qualify for the enhanced tier under Martyn’s Law, as a result of this existing framework, we don’t foresee a significant additional burden to the organisation of our major events.

11. That said, it is important the legislation does not duplicate or contradict the existing sports ground safety regime which establishes clear requirements on venues to assess and manage risk – including the risk of terrorism – and clear oversight roles for the Sports Grounds Safety Authority (SGSA) and local authorities.

grassroots tennis venues and events

12. As drafted, the Bill would bring the majority of LTA registered venues and the 11,500 LTA approved tournaments within scope of the standard tier. The legislation is therefore likely to place significant additional administrative and resource burdens on grassroots volunteer-run tennis clubs, venues and events at a time when recruiting and retaining volunteers remains a challenge, and they are already stretched by energy prices and cost of living pressures.

13. We are concerned that the additional compliance burdens on volunteers, clubs and venues, will lead to an exodus of volunteers, on which sport is reliant, and therefore a reduction in the provision of sport and recreation participation opportunities and events. This in turn, will undermine efforts to get more people participating in sport and recreation and to maximise the attendant benefits this brings in terms of physical and mental wellbeing, economic development and community cohesion.

14. At a minimum, comprehensive and clear guidance will be needed for the grassroots sport sector. But, given that the risk of terrorist attack is low for grassroots sport, in this context we support the Sport and Recreation Alliance’s call to explore with Government whether there could be some form of exemption for these types of premises and grassroots events from the requirements in the Bill.

June 2023