I am writing to provide some detail around the FA’s announcement on Monday 12th April that the new Step 4 division would be operational from next season.

These changes were originally announced three years ago, and planned to be in place for the 2020/21 season but implementation was delayed by COVID-19. However, the pandemic has accelerated the need for positive change and the opportunity has now arisen to implement the restructure.

The FA Executive submitted detailed proposals to the Alliance and Leagues committees whereby aggregated sporting data could be used to create an impartial process to allocate clubs to the new divisions for next season. By contrast, aggregated sporting data could not be used when it was decided to declare the 2019/20 season null & void.

Applying aggregated sporting data makes for a less subjective approach than an application process, whilst there is no precedent set due to the uncertain times, Clubs are not being relegated by using the data and the upward movement of clubs is to create new divisions only.

The proposals were accepted by both the Alliance and Leagues committees and, subject to feedback from clubs to the FA, the decision will be put to FA Council for ratification on 22nd April.

Background

The restructure comprises the creation of an eighth division at Step 4 (to be run by the NPL) and two new divisions at Step 5, with three fewer divisions at Step 6.

The changes create a 1-2-4-8-16 pyramid at Steps 1 – 5, mitigate travel issues at Step 4 (especially in the North East) and provide extra revenue opportunities from more localised fixtures.

FA NLS Regulations state that the power to implement a restructure is not vested in leagues directly, but in the Alliance Committee for Steps 1 – 4 and the Leagues Committee for Steps 5 – 6, at their sole discretion.

Why re-structuring now?

January’s NLS Club Survey provided the basis for the decision to curtail the 2020/21 season. The survey also highlighted clubs’ desire for changes to be made to the structure of the NLS as soon as possible.

Several proposals, including Project Non-League, were submitted during the survey process. These were all evaluated by the FA and different elements incorporated in a restructure which will benefit 110 clubs across the NLS. If the Step 4 element is delayed, only 50 clubs will benefit. Delaying the restructure until a full season’s playing records can determine promotion/relegation would see the NLS stagnate further.

The challenge has been to find a robust method by which clubs could be awarded places in the new system. The solution put forward by the FA, endorsed by the two committees, is to use aggregated sporting data from the 2019/20 and 2020/21 seasons.

Why this model/process?

Although the FA has sanctioned the use of aggregated sporting data from seasons 2019/20 and 2020/21, this solution was not available twelve months ago because it can only be used where league constitutions remain the same over the aggregated period.

Although league constitutions (i.e. clubs) were unchanged in both 2019/20 and 2020/21 season, this was not the case in 2018/19 season. Although the decision to declare the 2019/20 season null & void at Steps 3 – 6 was challenged, that challenge was unsuccessful.

This restructure is purely about filling the new divisions at Steps 4 and 5 so we are unable to fill other vacancies. When National League clubs voted to null & void the 2020/21 season at Step 2, no clubs could be promoted from, or relegated to Step 3. With no relegation at Steps 3 – 6, even if the aggregated sporting data solution were applied, promoted clubs could not be replaced, leaving divisions teams short and club revenues reduced.

The National League had already decided to defer the expansion of its Step 2 divisions to 24 clubs so their constitution will remain unchanged next season.

Club allocations 2021/22

If FA Council ratifies the Alliance and Leagues committees’ decisions, it will be a little time before we know which clubs will make up the new NPL division. Allocation is not strictly automatic; clubs have to apply formally and meet pre-set criteria which will be announced by the FA in due course.

Once the composition of the new division is known, we will be working with the FA to decide upon the Step 4 boundaries. These will, wherever possible, be based on minimising travel times and distance.

Is this a done deal?

Although both FA committees have endorsed the re-structure process, the decision is yet to be ratified by FA Council. The FA correspondence allows clubs the opportunity to make any comments by lodging them at NLS@TheFA.com by 16th April 2021.

All club comments will, as detailed in the FA’s announcement, be presented to FA Council for consideration. If FA Council decides to delay the re-structure, then it will be delayed.

I hope that the above of helpful. As always, should you wish to discuss any aspect of the reorganisation, please do not hesitate to call or e-mail me.

Kindest regards
Mark Harris
NPL chairman