Select Committee on Transport, Local Government and the Regions Memoranda


Memorandum by Kit Campbell Associates (PPG 05)

INTRODUCTION

  Kit Campbell Associates (KCA), Leisure Recreation and Tourism Consultants, submit this memorandum to the Committee based on our research on open space planning for the Scottish Executive, published as Rethinking Open Space (2001), and our work advising local authorities and other agencies on sport, recreation and open space planning in England and Scotland.

General Issues

  In order to set the context for our response to the specific questions on which the Sub-committee is seeking evidence, we wish first to highlight a number of inter-related general issues we believe a new PPG 17 should seek to tackle but largely ignores:

    —  The Definition of Open Space: as noted in the consultation draft PPG 17, the definition of open space in planning legislation is "land laid out as a public garden, or used for the purposes of public recreation, or land which is a disused burial ground". This definition is hopelessly inadequate and, as PPG 17 notes, "there are other kinds of public and private open space". The lack of a clearly stated and widely adopted typology of open spaces bedevils the whole issue of effective open space planning. Without it, different agencies use different terms and there can be a serious lack of clarity over both objectives and desirable outcomes.

    —  Planning Methodologies: very few planning authorities have developed a sensible approach to the planning of open space. Instead, many have simply adopted the National Playing Fields Association's Six Acre Standard for "playing space", although some have added a further component which goes by a variety of names such as "leisure areas" or "amenity open space". The main reason for this is quite simply that they do not have the resources to do much else. However, it beggars belief that the same basic minimum level of "playing space" is equally appropriate in areas as different as Shetland, Cornwall and the West Midlands. Levels and patterns of participation in sport and recreation have changed dramatically since the standard was first proposed in the 1920s and forms of outdoor sports provision which did not exist then—such as floodlit or artificial pitches—are now widely available. While the Standard is easy to apply, it results in the main emphasis in open space planning policies being on the quantity of playing space in relation to population—to the detriment of issues such as quality, accessibility and the contribution which attractive, well located open spaces can make to the key agendas of social inclusion, health, economic development, nature conservation, bio-diversity and the control of pollution.

    —  The importance of the new. Planning policies have generally concentrated on requiring developers to provide new on-site or contribute to new off-site open spaces. The enhancement of existing ones is a much lower priority and often largely ignored, as many planners see it as a management or maintenance issue rather than a land use policy one. However, of the total area of urban open space which will exist ten, twenty or even thirty years from now, probably well over 90 per cent already exists. By concentrating on the provision of new open spaces and little more than the protection of existing ones, the planning system is tinkering at the margins. It is also storing up long term maintenance funding problems for those local authorities which are willing to adopt and subsequently maintain new open spaces. One consequence of this is that a growing number of local authorities are refusing to adopt and, instead, require developers to make other arrangements for maintenance. Some of the mechanisms they use are unlikely to deliver high quality maintenance over the long term.

    —  Open space audits: the "Scottish version" of PPG 17 (NPPG 11, Sport, Physical Recreation and Open Space, published in 1996) recommends that planning authorities should undertake open space audits before framing their policies. This sound advice has been incorporated into the new draft of PPG 17. However, it has been largely ignored in Scotland, simply because of the resource implications, and is also likely to be ignored in England for the same reason. However, effective planning cannot proceed in the "statistical vacuum" identified by the Committee in its report on Town and Country Parks.

    —  Joined up thinking: the widespread use of the NPFA Standard means that planning authorities can adopt provision standards for "playing space" which may not be supported by other local authority departments, particularly those responsible for the management and maintenance of open space. The Committee's Reports on Town and Country Parks and Cemeteries emphasise that a key priority should be to reverse the decline in many existing parks and other open spaces. There is absolutely no sense in planning authorities requiring developers to provide new open spaces if existing ones in the same area are in poor condition and those responsible for them are starved of resources; it merely emphasises their poor condition.

    —  The assessment and use of commuted maintenance sums: planning authorities generally require developers to provide commuted sums. These are usually calculated as the average annual maintenance cost for existing open spaces, multiplied by a number of years prescribed in or linked to local plan policies. Accordingly an "X year" commuted sum should fund maintenance for X years and most planning authorities use a period of between five and 15 years. However, actual levels of maintenance expenditure are sometimes much lower than those used to determine the sums in order to "spin them out" for a longer period. In some instances, commuted sums may not be used for open space maintenance at all, but for some totally unrelated purpose. Both of these approaches are fundamentally dishonest, if understandable in the light of the significant reductions in local authority grounds maintenance budgets over the past decade or so. In addition, there is some evidence that Local Plan Inspectors are recommending planning authorities to use relatively short periods when assessing commuted sums. For example, Harrogate—a Council which has been "capped" for the past eight or nine years—proposed a 15 year period in its Local Plan. The Inspector recommended that "a period of five years is appropriate as this will allow the open space to become established".

    —  Measuring the performance of the planning system: the priority given by the government to reducing the time planning authorities take to determine applications for planning consent is fundamentally misconceived. The emphasis should be on the quality of decision-making and achieving a high quality, attractive environment and "place-making". It can take some time to negotiate the most appropriate form of open space or sport and recreation provision with a developer. This is especially the case where there is a need to enhance existing open spaces or sports facilities and therefore cross-department negotiations within the local authority as well as negotiations with the developer. The pressure to determine applications quickly can make it difficult or impossible to achieve the optimum or even a good solution and pushes planning authorities towards the application of simple but possibly inappropriate provision standards for new provision.

    —  The condition of existing open spaces and sports facilities: decline accelerates, but reversing it can be a long and slow process as each step change in quality can make the next "noticeable difference" more difficult to achieve. The problem of steady and accelerating decline in the condition and quality of parks identified in the Committee's Town and Country Parks report applies every bit as much to publicly funded sport and recreation facilities, for which maintenance budgets have also been severely curtailed. Research by KCA for sportscotland has identified the cost of repairing and maintaining Scotland's public indoor pools over the next twenty years as around £550 million. As England's population is around ten times that of Scotland's, the equivalent figure for England may be around £5.5 billion. There is a real danger that occasional capital investment—made possible by some Lottery funding programmes and the "bidding culture" in which local authorities have to operate—becomes a substitute for adequate maintenance. This leads inevitably to a cycle of capital expenditure, followed by steady decline then more capital investment and so on.

    —  Provision for children and teenagers: most planning authorities require housing developers to provide facilities for children's play on the basis of the NPFA Standard. This has a number of serious drawbacks. For example, many local residents oppose the provision of play areas; children want to play in the street rather than in fairly "sanitised" play areas; and local authorities cannot afford the regular inspection and maintenance of play equipment required by the relevant European Standards and so remove the equipment after a few years, leaving isolated areas of safety surfacing. As for teenagers, their needs are largely ignored, with the result that many older adults perceive groups of them "hanging about" as threatening. The lack of designed provision for teenagers, and activities such as skateboarding and roller blading, means that they use any area which is suitable and cause damage or scarring to buildings and hard landscaped "edges".

What is needed to overcome these problems is:

    —  Greater clarity in relation to desirable outcomes.

    —  A sensible typology of open space which identifies the importance and role of all the various types of open space.

    —  A much better approach to the planning of open spaces and the setting and use of provision standards.

    —  A shift in priority from the provision of new open spaces or sports facilities to the sustainable enhancement and regeneration of many which already exist. This shift is fundamental to the urban renaissance.

    —  The promotion of child and pedestrian-friendly "Home Zones", in which housing environments incorporate specific shelters and other facilities for teenagers, supplemented by fewer but larger and more stimulating equipped play areas for younger children.

Desirable Outcomes

  In Rethinking Open Space, we recommended that the key open space outcomes which planning authorities and their partners should be seeking are:

    —  Comprehensive networks of accessible, high quality and sustainable green and civic spaces . . .

    —  Which contribute positively to the image and overall strategic framework for development in their areas, . . .

    —  Promote both economic development and social inclusion . . .

    —  With each individual open space planned, designed and managed to serve a clearly defined primary purpose . . .

    —  While also delivering important secondary benefits, such as a sense of place, economic development, bio-diversity, nature conservation, enhanced air quality and the control of pollution and flooding.

  These outcomes are equally applicable if "sport and recreation facilities" are substituted for "green and civic spaces".

Open Space Typology

  The table in an appendix summarises the "urban" typology we recommended in Rethinking Open Space, together with the key objective of each different type of open space and the most appropriate planning methodology. This typology has to be modified for use in rural areas; for example, there will usually be relatively little need for parks and gardens, natural greenspaces or allotments. In addition, local aspirations, rather than assessed demand, will often drive the provision of sports facilities such as pitches and recreation grounds in rural areas.

The Development Control Process

  The impact of planning policies arises when they are implemented through the development control system. The "decision model" below sets out the way in which planning policies for both open space and sport and recreation should be applied:


Provision Standards

  Most planning authorities have adopted very simple provision standards. However, the "decision tree" approach above indicates that they should include at least:

    —  A quantity standard—the NPFA format of X hectares (or sq m)/1,000 is the easiest way to express a quantity standard for some types of open space and most types of sports and community facilities, such as swimming pools, sports halls and community centres or village halls, although a better approach to sports facilities is along the lines of 1 football pitch per X,000 people, 1 cricket pitch per Y,000 people and so on. Such quantity standards must be driven by local needs and not simply copied from elsewhere.

    —  A distance threshold—the distance that typical users are willing to travel to each type of open space. Distance thresholds should also be locally determined.

    —  A quality standard—a locally agreed "vision" against which the quality of any existing open spaces or sports facilities can be measured in order to determine the need for enhancement.

  Ideally, provision standards should also contain:

    —  A minimum acceptable size, required to prevent the provision of open spaces or other facilities which will be too small to be of benefit to local communities, or unnecessarily expensive to maintain.

    —  A site area multiplier—most sports facilities and children's play areas require a site area significantly larger than the actual facility.

    —  Normalised capital, establishment and maintenance costs—to be used when assessing either Section 106 contributions or commuted maintenance sums.

OUR RESPONSE TO THE COMMITTEE'S SPECIFIC QUESTIONS

The contribution of the revised PPG to strategic planning for sport, open space and recreation

  There is an important point to be made in relation to the difference between policy statements and "process" advice. Like other PPGs, PPG 17 contains a mixture of the land use policy outcomes the Government wishes to see the planning system deliver and advice to planning authorities on processes. Generally speaking, there is fairly widespread support for many of the policy outcomes and therefore planning authorities are reasonably good at incorporating them into their policies. Where they are not included, Planning Inspectors ensure they are taken into account in the appeal process. However, the process advice in PPGs is followed much less often, although effective processes are fundamental to the proper operation of the planning system. If they are ignored, development plans could consist of little more than a bound set of PPGs plus a key diagram or proposals map. The limited staff and other resources available to most councils means that, however willing, they do not have the ability to undertake the considerable amount of work called for in Chapter 4 of the draft PPG 17, Identifying Needs and Opportunities. The fact that the process advice in the new PPG 17 is not particularly clear as to what local authorities should actually do is a separate but related issue.

  The implication of this is that strategic planning is often driven not by any analysis of local needs, or even local circumstances against a background of national policy, but by "parachuted in" and possibly inappropriate provision standards. In the case of open space, strategic planning responds to those clearly stated policy outcomes in PPG 17 with which councils generally agree (eg the protection of playing fields) and the 75 year old NPFA Standard. As for sport and recreation, The Effectiveness of Planning Policy Guidance on Sport and Recreation (DETR, 1998) notes that "The district sport and recreation strategies studied had little content directly related to land use planning matters. In some authorities the links between planning and leisure departments were poor". The Effectiveness of Planning Policy Guidance on Sport and Recreation made around forty recommendations for changes to PPG 17, but almost all have been ignored in the current draft.

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

  The revised PPG fails completely to tackle the fundamental issue of an appropriate open space typology and, following on from this, the objectives of providing open space and sensible planning methodologies to use. Instead, the terminology of formal and informal facilities used in the draft is inconsistent and muddled and the "process" advice fairly vague. An important issue which needs resolution is whether sport and recreation should be seen as a land use in its own right, or—at least for outdoor sport and recreation facilities such as pitches—a sub-set of open space. The danger of regarding sport and recreation facilities as a sub-set of open space is that there is an implicit assumption that playing fields contribute significantly to local amenity. In reality, there is little amenity in large areas of flat mown grass, while dog-walking on playing fields can result in fouling which is then unpleasant for players, especially those involved in rugby.

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

  The PPG's treatment of open space in Local Plans should contribute to the protection of many open spaces; but the urban renaissance will depend on their improvement and not simply their protection. The first step in doing this will be to determine what open spaces exist, where they are, how they are used, what condition they are in, how they are managed and maintained, and what will be needed to improve them and then keep them in at least their improved condition. As the Partial Regulatory Assessment at the end of the draft PPG 17 notes, "local planning authorities are expected to make assessments of recreational needs in their areas, and set standards for future provision. But this is an expectation of existing guidance, and the revision will only emphasise the importance of this process in order to secure the proper planning of their area". Agreed; but the fact is that probably the vast majority have ignored this aspect of the current guidance. Simply repeating it—and commenting naïvely that the new PPG 17 "should not impose any further costs"—is unlikely to encourage them to follow it. PPG 17 will be cost-neutral only if planning authorities continue to ignore its process guidance. At the same time, Best Value calls for significant and continuous improvement, although many Best Value Inspections have concluded that local authority grounds maintenance services are "unlikely to improve". No local authority we know aims to serve its local community poorly and this is destroying what little morale there is left in some departments. After the massive reductions in revenue expenditure highlighted in Town and Country Parks and the Public Parks Assessment (HLF, 2001), achieving significant and continuous improvement depends ultimately on resources.

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

  A key "government aspiration" in the Urban White Paper is to find ways of "improving the quality of parks, play areas and open spaces and make them cleaner, safer and better-maintained places". In order to determine how best to deliver against this aspiration, it has set up the Urban Greenspaces Task Force, which is due to report in the spring of next year. Its main purpose is to assist in developing a vision and proposals for the sorts of parks, play areas and open spaces the Government wants to see created and how they should be managed and maintained. This vision should obviously be at the heart of open space planning policy. Why then is the Government, ostensibly interested in promoting "joined up thinking", seeking to launch a new PPG 17 now which ignores these issues? In addition, the draft PPG17 largely continues the traditional emphasis on new open space provision and in paragraph 62 indicates only that "For small developments it may often be appropriate for the developer to make a contribution to the establishment or enhancement of a nearby sport or recreation facility". Why not parks and open spaces as well?


 
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