Select Committee on Transport, Local Government and the Regions Minutes of Evidence

Examination of Witnesses (Questions 280 - 299)




  280. Those figures go back to 1938. In 1938 most children could pretty safely play in the street outside their house. There must have been a huge amount of football and cricket played in the streets. Very few streets are now safe for children to play in. Should not the figures take into account what you have just said?
  (Mr Garber) Could I possibly deal with this in two parts, then if Don Earley could follow on. Yes, you can go back to 1938, but there was a clear change in what is on our streets now. The level of car ownership is significantly greater and the speed of vehicles has changed, and that has changed what is available. Nevertheless, within those strategies the NPFA introduced a very clear guidance in 1992, where opportunities would exist within urban areas and within streets by facilitating through design areas of play that could meet a safe area of activity within those; by traffic calming measures being introduced; by small areas of activity that could be controlled and contained relating to a pedestrian way; where speed of vehicles moving through those areas were functional. Indeed, this follows on from a system called Woonerf in Holland, which was an area very much involved in the involving of such areas where there was a clear linkage between use, activity and movement.

  281. That sounds all right, but I cannot think of any streets in Denton and Reddish that have been made safe as a result of things like that.
  (Mr Earley) The indications in the work that has been undertaken by Oxford Brookes of the NPFA Standard may be on the low side, and in certain areas it should be higher. I think that is probably a matter for the planning authorities once they have undertaken their local investigations. We mentioned the possible increase in participation of urban areas because of more modern facilities. The Six Acre Standard is a normative standard which gives a degree of consistency, I think, which is helpful for planning authorities and to developers alike. In the detail it could be improved upon.

Dr Pugh

  282. But we have the same Six Acre Standard for areas as diverse as Shetland, the Isle of Wight and the West Midlands. Is that not a nonsense?
  (Mr Earley) I do not think I would agree that it is a nonsense. First and foremost, I would like to differentiate between children, play and adults. I think it is very arguable that the needs of children, wherever they are, are universal. There is a need for children to be able to play safely out of doors, outside of the home and garden, and it does not matter where it is.

  283. Some children have a huge rural hinterland and some have narrow streets.
  (Mr Earley) A huge rural hinterland is not always available for them to take advantage of in terms of being able to play freely and safely. There are dangers in rural hinterlands in the same way there are dangers in the open streets. I do think the case is there and it is arguable. In the 1989 edition of the Six Acre Standard that debate was entered into and discussed. When we come on to matters to do with provision of outdoor land for sport the point that you make is a sound one. There we would again turn to the fact that local assessments need to be undertaken. We would advise a three-pronged approach quite simply for outdoor sport: the first is the Six Acre Standard, or a standard determined locally per thousand population for the land overall; the second would be so many pitches for, say, football, cricket, hockey or netball per thousand population; and the third one would be an assessment of supply and demand for facilities and space for those different activities. If you take one of those—if you take the Six Acre Standard alone—you are likely to end up with a far more inaccurate position than if you try all three. What we would urge is that planning authorities actually try all three.

  284. It sounds as if football is the guidance essentially rather than some sort of very fixed rigid rule. That would obviously make it more difficult for local authorities to formulate their own local standards, would it not?
  (Mr Garber) I do not think that is the case. First of all, I think it is crucial that there is an overall standard. It is no different in terms of the content within PPG17 and the reference there to the way in which one would look at uniformity of guidance with reference to parking. There are two aspects: first of all, I think it is important that there is an overall requirement and an overall standard by which every community can measure a need; and, where there is going to be provision, where that measure can be quantified. Secondly, it does not preclude authorities indicating and assessing any deficiencies. It is deficiencies that then can be addressed again through the planning process by reference to the justification through Circular 1/97 as to whether there are other needs that need to be addressed. The importance of conformity on a national basis is crucial, but the deficiencies still have to be addressed within the local authorities; and the way in which they address them has to be both quantified through their own needs and also assessed as to how they will meet that demand.

  285. You are not against the formulation of local standards, but you would expect them to be consistent with your rule?
  (Mr Garber) I am not in favour of local standards—to the extent that I believe it is crucial that there is a general conformity to a national standard. What I am not removing is the importance of local authorities identifying shortfalls in provisions and finding mechanisms of how those shortfalls and provisions are made. That can be achieved through a number of ways—whether through a development process, where it can be justified against the background of genuine planning gain. You have to find ways of redressing the deficiencies but, in the first instance, it is quite inappropriate that one should be looking at markers which for one part of the country (because of a local agenda) should be in one area, against another area where they say, "We don't need that; we think there's enough". I think the actual control through a mechanism of an NPFA Standard—which has stood the test of time, and stood a very big test over the last ten years where inclusion in policies has been fundamental to the success of achieving standards within authorities and the fact they have to comply through the development process of section 54(a) of the Planning Act—means that there is a clear foundation and justification for a clear national planning standard.

  286. Is there not a weakness in the standard , because it is purely a quantitative standard and not a qualitative standard? Do you think PPG17 could do any better?
  (Mr Earley) I think it is incorrect to suggest that the NPFA Standard is a quantitative standard. If you go back to when it was first published—

  287. It is incorrect. It does not say anything about the quality of the playing fields but the amount of playing fields per head of population. That is a quantitative standard, is it not?
  (Mr Earley) No, I do not agree with you.

  288. I do not know what a quantitative standard is then.
  (Mr Earley) There is a quantitative standard, but if you look in the body of the Six Acre Standard, in the present one as published in the appendices or in the new one which I have not made available to the Clerk yet, if we are talking about playing fields we talk about issues to do with drainage, gradient, orientation, and a whole range of issues which bear upon the quality of those facilities.


  289. Those bits get forgotten, do they not?
  (Mr Earley) They may get forgotten. I would willingly acknowledge that in the past the NPFA has probably done the cause and itself a little disservice by putting them in as appendices; but now they will be brought forward into the body of the text. My colleague, Mr Garber, may want to elaborate, but the same applies in terms of what we say about children's access and needs.

Dr Pugh

  290. A local authority might fail on your standard because they presented very, very high quality playing areas but simply not enough; and another local authority would pass on your Standard by producing acres of scrubland, almost unusable?
  (Mr Earley) Again, I do not agree. In the introduction I think we talked about outdoor playing space, whether it be for recreation generally, sport or play, as being land suitable for its intended purpose, size and nature. Having said all that, there may be a tendency to look superficially at the quantitative issues that we are talking about and not recognise the importance of quality of facilities locally for people.
  (Mr Garber) Could I just expand on that. One of the key issues that was addressed in 1992, and has been expanded on in the current document, was the importance not just of looking at the quantitative factor but, more significantly, of the qualitative factor. We were looking at the movement of young children and youths from their homes to the area of activity. When you look at that in terms of location of dwellings to the location of the facility, the walking or cycling time, depending on sustainability and ensuring that those provisions are made on a dimensional basis both in radial terms but also a factual walking time of minutes, that related specifically to age groups. We categorised and tested this with young children and, looking at gradients, you actually ensure that the qualitative factor comes into it. While the quantitative considerations remain and you are looking at it overall, what we are ensuring it is that the provision is in the right place to meet the needs of those who need to use those spaces.


  291. You have defended yourselves very successfully, but how far does PPG17, as proposed, carry your defence forward?
  (Mr Earley) Could I make a general remark first and foremost. I think PPG17 is not helpful enough, because it is not only the Six Acre Standard but the recommendations that came originally from the GLC and then promoted by LPAC that were referred to in the evidence given by the lady from the Greater London Authority last week. There are also recommendations made in terms of accessibility to open space by English Nature. It seems to me what PPG17 should be doing is to make clear reference to the work of other organisations where it is considered to be appropriate; to underline the strengths; if need be to make one or two comments about reservations; but to give clear reference to a bibliography, which is not there at the present time; and, as it did previously, to give illustrative examples which it did before. What is needed is, I think, a clearer framework for planning authorities, developers, the community, everybody so that they can make their own judgments about issues for the future. I think that is what we would like to see as the National Playing Fields Association.
  (Mr Garber) The weight of that is, within local plans (which are in a sense the generators of what comes forward) is a general background/documentation by reference to PPG17; but the actual policy is that that ensures deliverability of the facilities are very much set against the NPFA Standards; and it is important having that direct correlation between the standards, policies and strategies of the NPFA linked through to PPG17 that will give weight. The weight then follows through to the planning process and the need for compliance with local plans, structure plans and the like.

Mrs Ellman

  292. How can we deal with the issue of maintaining facilities, particularly children's play areas?
  (Mr Garber) Historically I think there have been problems, and I will come back to that in a moment. It may be helpful just to give the background. Apart from my role with the NPFA, I am Planning Director of Britain's leading house builder, so I do have a direct understanding of the problems and the application of overcoming those problems. Currently one has to assess where new provision is made, particularly if it is relating to developments, that first of all you meet the standard that is set out in terms of play provision and recreation provision. The local authorities quantify through maintenance costs what is required to ensure that maintenance is going to be delivered over a 10-15 year period, whatever satisfies them. The multiplier is projected, it is indexed-linked, and developers are required to pay an appropriate commuted sum secured by planning agreement into the authorities. While I have no issue that it should go into a wider fund and get maximum interest benefits, what is crucial (because every single space is different) is whether topographical considerations are there to be conserved, the proximity of closeness to footpaths, whether it is cycleways, whatever it may be, every one is different—therefore the calculation for maintenance for commuted payments is different in each case. What is essential in my view is that there must be a commitment to ensure that there is a dedication of those funds relating to those spaces. What happened historically, and we are living in a legacy where spaces have not been maintained, or there are particular problems with local authorities in maintaining, is that there was a fund that was provided but it was not dedicated or committed to the maintenance of the specific spaces and it dwindled away. At the end of the day you have problems with maintenance. I think the other point which comes in which is against the historic provisions, against what is not applied (and this goes back to the answer I gave to Dr Pugh), we now look at qualitative space in the right location in its proximity to dwellings. No longer do you find spaces that are stuck around the corner, that are hidden and have no function and are not supervised, where parents will have concerns. You have the functional space, you have the quality provision, you have the quality in terms of the technology that goes into the surface materials, and the safety of equipment that goes in there, and you have the modern technology in terms of the limitations that one now has to consider in terms of the needs and demands for maintenance. Those, I believe, have positively been addressed. It is something that has emerged but I understand and appreciate that historically there has been a problem.

  293. How specifically can the responsibility for the ongoing maintenance of, for example, children's play areas be written into planning approvals?
  (Mr Garber) There are two factors: first of all, it is now common (and I say this from dealing with matters all over the country) for local authorities to seek commuted payments for the maintenance of play areas. They would range in terms of the quantification of between 10-15 years with interest, and that goes into the sinking fund which then provides for the ongoing management beyond the 15 year period. It is happening and it is, I think, universally happening throughout the country. It certainly was not happening but the way it is addressed now it is. It is a requirement and it is very much a standard requirement through the policies of local plans which set up in specific terms that developers will enter into an agreement related to a particular site to ensure that provision is made.

  294. Why then do we have so many examples of play areas which are either not maintained or in fact cease to be equipped because of maintenance issues?
  (Mr Garber) This goes back to the historical point where, unfortunately, commuted payments were not dedicated to the specific areas. That is not happening. It was a fund it was put in. There was no real examination as to the costs as to what was required. Authorities are very much more alert to what is now required, and I think justifiably so. They will look at a) the type of equipment, the type of surface, and they will look, through experience, at how frequently it has to be replaced, how frequently it has to be managed, how frequently it has to be upgraded. Historically it was not there. It is an ongoing problem. What one has to look at, clearly, is where enhancement can take place within new developments; where they are in proximity to older facilities that you ensure that the right provision is there meeting that requirement and to manage it and maintain it. This issue of meeting the needs of the community has to be seen as a legacy that is going to be ongoing, rather than a matter that has been forgotten. It is the forgotten areas, I agree, that need to be addressed.

  295. How many local authorities meet your minimum standards for equipped children's' play areas?
  (Mr Garber) I think since 1992—I think it goes back far more than that—the very fact that in 1992 it was not just an NPFA guidance dealing with outdoor play spaces, it was a design guide which set up in practice how that provision should be met. Certainly from my own experience, on both sides, it is now a provision that is being required.


  296. You were asked how many actually meet the standards—any?
  (Mr Garber) I would find it impossible personally to answer if one is looking at quantification over the years.

Mrs Ellman

  297. How many now?
  (Mr Garber) In the last ten years, where there has been an obligation to meet those requirements that has been met.

  298. Are you saying at the moment all local authorities meet your minimum requirements?
  (Mr Earley) I think what we have to say and acknowledge is that there has been no research across the board into how many local authorities in the whole of their areas of administration meet the NPFA's Six Acre Standard. What Paul has been saying quite clearly is that, where there have been new developments a great deal of those developments in recent years have conformed to the recommendations of the NPFA; but they are not necessarily going to be able to meet any deficits that were there before. Having said that, I am not in a position to give examples to you.

Chris Grayling

  299. Mr Garber, you mentioned briefly your own role as somebody who works in the development business and also your role in the NPFA. To what degree do you think the objectives of the two different groups are the same, or are they different?
  (Mr Garber) I think they are the same. Any house company, in my opinion, is creating communities for the future and it is their responsibility to provide the facilities and the environment for future occupiers. That is the legacy that is expected and should be expected. The concerns that are now addressed, quite rightly so, are to ensure that those provisions have a quality in terms of the type of facility that is there, and a legacy which any developer worth their salt should ensure is met. I do not see a conflict. I know the HBF have been here. The HBF have been involved with the NPFA in the new guidance in a positive role. The fact that you have the industry which I am involved in fully supporting the objectives and the aims that the NPFA are now trying to achieve I think is testament to what is the commonality between the two.

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