Select Committee on Transport, Local Government and the Regions Memoranda


Memorandum by City of York Council (PPG 04)

1.  INTRODUCTION

  1.1  This is a response from the City of York Council to the request for further comment on the Draft PPG 17 (Sport, Open Space and Recreation).

  1.2  In general the PPG brings with it a new and valuable focus on local audits of both quantity and quality. It is important that national standards are also set but as long as a degree of discretion remains the PPG will allow for local circumstance.

2.  THE CONTRIBUTION OF THE REVISED PPG TO STRATEGIC PLANNING FOR SPORT, OPEN SPACE AND RECREATION

  2.1  The PPG's effectiveness is reduced by the large amount of planning jargon within. This makes the PPG less accessible for those outside of planning circles. An example is the term "recreation" which is used throughout the PPG. However there is no clear definition of what recreation actually means—is it intended that for the purposes of this PPG it covers physical sports or could it mean other forms of recreation, such as going to the cinema, pubs, clubs etc.

  2.2  The proposals for an audit of open space and leisure facilities is fully supported. It is recommended that the PPG includes at least a minimum requirement for the provision (especially of open space) which would be helpful in guiding local planning authorities. If standards are left totally at the discretion of local authorities this may lead to wide variations in standards between areas (especially neighbouring authorities).

  2.3  While it is important for there to be some sort of national standard and guidance the PPG must withhold a degree of flexibility to allow for local distinctions. As far as paragraph 51 of PPG 17 is concerned, it seems to offer as much flexibility as possible without the need to re-consider the content of PPG 2.

3.  THE CONTRIBUTION OF THE PPG TO THE PROVISION OF HIGH QUALITY NEW OPEN SPACE AND SPORTS OPPORTUNITIES

  3.1  The release of non-public open space plays an important part in providing new open space and sport opportunities. Whilst it is accepted that schools can play an important role in providing facilities for sport and recreation, so can voluntary sports clubs and other community providers, yet there is little emphasis on these providers.

  3.2  The PPG holds very little guidance with regards to the requirement of open space along with non-residential developments. This is a difficult topic and having had discussions with groups such as the NPFA and Sport England I have found there to be a great deal of uncertainty. The main areas that should be addressed are:

    (a)  Should non-residential developments be required to provide open space? Currently you ask that "all major developments" should provide a degree of space. However from a survey of local authorities I have found that very few actually enforce such a requirement as they feel it unreasonable. Whichever view is correct it is important that there is a degree of consensus between the Government and the Local Planning Authorities. There is obviously much confusion over this issue and a clear position statement would be of great benefit.

    (b)  What types of non-residential developments should be required to provide open space (eg all employment generating uses or should, for example, hotels and supermarkets that have fewer employees but many users be excluded?)

    (c)  What is a realistic level of requirement? Should provision be related, for example, to the number of employees, the site area, development costs or gross floor space?

    (d)  If you feel that it is only suitable for a basic note to be incorporated in the PPG then I suggest that other research is carried out, so as to form a consensus view with other organisations.

  3.3  There may be circumstances where open space needs to be enlarged to become more practical and reference should be made to these circumstances, for example if an underused or derelict Brownfield site lies adjacent to a small area of open space, the extension of the open space could have positive benefits all round and should be encouraged. While the PPG gives sufficient weight to the provision of new open space and recreation provisions it needs to find a balance between this and the development/expansion of existing facilities to ensure long-term sustainability.

4.  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

  4.1  While there are reference documents for local planning authorities to assess requirements for the provision of open space for active recreational purposes (NPFA and Sport England guidance) there is not such a point of reference for amenity open space. A base figure would be useful in shaping requirements. Without such a reference there are large differences between authorities, from my experience ranging from 0 to 0.8 ha (on top of the NPFA 2.4). While I appreciate the need for local uniqueness some frame of reference is vital if we are to achieve any sort of national standard. To support this, target access criteria would also be useful.

5.  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 ENVIRONMENTS

  5.1  Enabling private facilities to become available for public use could play a primary role in improving living conditions. However this is a difficult area to handle. For example would the loss of a degree of private open space be looked on favourably if along with a permission the remaining private space was brought in to the public realm. For example a private sports club applies for planning permission to build a new annex to their current club house, to be located on one of their football pitches. If permission is given for this development the club will open up another of their pitches for public use. Would this be acceptable? There will be a loss of the total stock of open space but the proposal will bring an increase in the total amount of "public" open space. The question really comes down to how local planning authorities should value private open space as compared with that in the public realm.

  5.2  How authorities should deal with applications for facilities that would benefit an open space, but will also result in the loss of open space should be clarified. Could a smaller open space with excellent built facilities be more desirable than a large open space with a lack of facilities. If so, this needs to be clarified.

  5.3  The guidance on locations for particular sport, open space and recreation facilities needs further work. Whilst it is accepted that in many circumstances, the location of intensive sports facilities in City centres or edge of centres should be encouraged, the importance of intensive/well used facilities in surrounding settlements should not be overlooked. For example, there are a number of well used sports clubs with extensive facilities in larger villages within the York area. The importance of these facilities in the community needs to be accepted and encouraged.

  5.4  Paragraph 45 of the PPG places an emphasis on the importance of school facilities to ". . . develop and extend sport and recreation opportunities for the community . . .". However, this is not always achievable (for example, as a result of school policy, or location). Therefore, it is equally important that other providers are encouraged to develop new (or extend existing) facilities, this should be encouraged within the PPG.

  5.5  The emphasis placed on the accessibility of open space is an important addition to the PPG and the guidelines for distances may also be very beneficial. However, it must be stressed that these distances must be realistic and achievable. For strategic guidance using a radius from the development site may be enough and will simplify area studies. However, when dealing with actual planning applications, local authorities should be encouraged to assess development sites access to open space on a site-by-site basis. This will lead to more detailed data gathering and could make for more efficient provisions of open space. In this way authorities will be able to assess real "on the ground" walking distances and take account of physical obstacles such as main roads, rivers and railway lines.

  5.6  It is considered that s 106 agreements have sufficient scope for the maintenance of open space. However difficulties do arise when trying to secure maintenance payments from developers towards off site open space provision. To prove that an open space is principally for the use of the population of a development (in line with Circular 1/97) is very difficult. Maybe an alternative way of helping to secure monies for providing and maintaining open space and sports facilities would be to introduce a standard national levy on each dwelling built in the country, which would go towards financing facilities on a local basis.

6.  THE CONTRIBUTION OF THE PPG TO ACHIEVING THE GOVERNMENT'S ASPIRATIONS ON URBAN PARKS AND PLAY PROVISION AS SET OUT IN THE URBAN WHITE PAPER

  6.1  As the aspirations will not be published by the Urban Green Spaces Task Force until March 2002 it is difficult to assess the paper against this. It will however be very important that the two things are unified and the publication date of this paper should play an important role in any further decisions on time-scales for the PPG.


 
previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2001
Prepared 16 October 2001