Memorandum by The British Gliding Association
The British Gliding Association's original submission
to the DETR on 11.06.01 highlighted the inadequancies of the Revised
PPG 17, particularly those of failing properly to recognise the
needs of sport, both generally and specifically and the failure
to give proper guidance to planning authorities or to set standards
which will assist them in making planning decision.
The Revised PPG has been far too general in
its approach and fails to provide clear guidance. DETR has provided
a flat and defensive approach to sport and fails to reflect Government
Policy for Sport (A Sporting Future for All). It fails to acknowledge
the need to increase participation in sport by young people or
the wider community benefits that can be attributable to sport
if managed enthusiastically and well.
We accede to the request not to repeat our earlier
submissions and assuming that those observations have been noted
for future reference, we wish to devote this memorandum to the
specific points raised by the House of Commons Select Committee.
The contribution of the revised PPG
to strategic planning for sport, open space and recreation.
The revised PPG fails to justify need for sport
or to provide any detailed guidance or specify requirements for
The Revised PPG fails to set standards on allocation
of open space (eg National Playing Fields Association (NPFA))
6 acres per 1,000 population yardstick in old PPG 17) and fails
to upgrade or improve upon earlier recommendations.
The contribution of the PPG to the
provision of high quality new open space and sports opportunities.
The Revised PPG 17 provides an excellent opportunity
for meeting the needs for sport through the planning system but
in failing properly to specify those needs, it fails to exploit
The extent to which the revised PPG
is successful in addressing the newly included subject of open
space and reconciling it with sport and recreation.
Open space is not a newly included subject?
The 1991 version of PPG 17 Sport and Recreation set standards
as guidelines for the needs for publicly accessible open space
and quoted the National Playing Fields Standards. In that respect
the 1991 PPG 17 gave better guidance to local authorities than
does the Revised PPG.
There appears to be no enthusiasm for sport
as a legitimate land use and makes no attempt to justify the allocation
land for sport or the recognition of Significant Areas for Sport
The extent to which the revised PPG's
treatment of open space will contribute to the urban renaissance,
the protection and improvement of open space and improved living
Urban authorities are failing to meet earlier
NPFA guidelines and urban open space is being built up with loss
to the environment. There is much poorly managed land under local
Guidance is required as to management standards
for open land under control of urban local authorities. Many are
failing to meet their obligations but the Revised PPG sets no
standards. Injurious weeds, dumped litter and rotting car bodies
do not improve living environments, yet that is happening on the
urban fringe of many cities. Without proper guidelines, might
that be considered as acceptable? Too frequently, areas of open
space are taken over without management and attempts are made
to justify the subsequent dereliction under the guise of "conservation".
To what extent is the dereliction of farmland
under the control of local authorities a reflection of poor management
and to what extent does it reflect of poor planning guidance?
The contribution of the PPG to achieving
the Governments aspirations on urban parks and play provision
as set out in the Urban White Paper.
The emphasis in the Revised PPG is upon the
allocation and protection of open space in urban areas. Chapters
three, five and six provide some useful guidance to planning authorities
which in many ways is clearer than when dealing with open space
in rural areas as in Chapter four.
In responding to the DETR consultation paper
on the Revised PPG 17, this Association commented upon the lack
of provision for airsports. The omission of aviation is already
being raised at Public Inquiries. On 11 September 2001, at the
Public Inquiry on Rochester Airport in the Medway Local Plan,
the Inspector sought clarification as to why aviation interests
had apparently been excluded from the Revised PPG 17.