Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by National Playing Fields Association (PPG 12)

  The National Playing Fields Association ("NPFA") is an independent charity. It is the only national organisation which has specific responsibility for acquiring, protecting and improving playing fields, playgrounds and playspace where they are most needed and for those that need them most, particularly children of all ages and people with disabilities. The Association leads the campaign to have adequate recreation space available for everyone within easy reach of their homes.

  The NPFA welcomes the inquiry into the draft PPG 17: Sport, Open Space and Recreation.

  The NPFA has responded directly to the Department for Transport, Local Government and the Regions about the draft revision. While it is not our intention to repeat the NPFA's response in this memorandum, a summary of our views is provided below.

    —  The draft suffers from lack of clarity and is insufficiently clear to achieve the intended purpose of providing clear, practical guidance (paragraphs 7 to 9 of the NPFA's response).

    —  The content relating to standards and the assessment of needs requires more detail and should necessarily refer to the NPFA's own recommendations on land for outdoor sport and children's play, known as "The Six Acre Standard" (paragraphs 10 to 20).

    —  The content relating to protecting open space, though based on sound objectives, sets out an approach which the NPFA fears is unworkable (paragraphs 21 to 25).

    —  Insufficient regard and reference is made to children's play and the use by children of the wider environment in which they live (paragraphs 26 to 28).

    —  The terms and definitions used are very confused and inconsistent (paragraphs 29 and 30).

    —  Issues relating to access and location merit further attention (paragraphs 31 and 32).

    —  Scant regard is paid to the needs of the disabled (paragraph 33).

    —  Landscape and design issues are, unfortunately, largely ignored (paragraphs 37 and 38).

  In Press Notice 2 as published by the Committee a number of questions are raised. The NPFA's summary views are given below.

    —  PPG 17 is a document of fundamental importance for strategic planning for sport, open space and recreation but it needs to provide clearer, useful national guidance that can be adapted to take account of local needs and circumstances. It fails at the moment.

    —  While it is generally positive that the guidance refers to "Open Space", consideration of such space needs to be carried into the body of the document in more detail, with greater attention given to matters such as amenity, landscape, ecology and bio-diversity.

    —  The PPG should provide greater guidance on standards and other tools which can assist the recreational planning function relating to all forms of open space. Only when this has been done can the interrelationship between different forms of open space, their value and function be understood more fully and addressed on a strategic basis.

    —  Little mention is made of urban renaissance in the document. The approach to the protection and improvement of open space, though very much supported in principle, will predictably be too complex in terms of the requirement for standards for all forms of open space. Will it be workable?

    —  It is felt that the PPG should and could contribute a great deal more to the Government's aspirations on urban parks and play provision.

  By way of conclusion, the NPFA's view is that the PPG requires a great deal of revision and improvement. It currently falls short to the extent that the next revision should again be issued as a consultation draft, rather than as revised guidance.

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Prepared 16 October 2001