Supplementary memorandum by National Playing
Fields Association (PPG 12(a))
PPG17: SPORT, OPEN
As a final follow-up to our evidence to the
Sub-Committee, I am writing to affirm the NPFA's position on a
number of issues.
1. There needs to be clear, proper and common
definitions and typology of open spaces for planning purposes.
2. The DTLR has been offered assistance
by the NPFA, and no doubt other bodies as well, but refused it
to date. Their approach has not been inclusive. The draft has
suffered because of this. A notable example is the imbalance between
consideration of open space issues in the broadest sense and specific
3. The existing PPG 17 gives status and
weight to the NPFA's Six Acre Standard. The draft revision diminishes
these attributes significantly. In a recent sample survey of local
plans, 33 out of 42 (79 per cent) of planning authorities make
reference to the Six Acre Standard. If the draft is left unchanged
then the DTLR will have undermined the Six Acre Standard, failed
to provide any better alternative approach and destabilised the
planning policies of up to 80 per cent of planning authorities.
The Guidance needs to name the NPFA's standard, give clear reference
to it in the bibliography and provide it as an annex as illustrative
material. The same may apply also to other useful national standards,
capable of local adaption. A clear "health" warning
needs to be given to planning authorities not to use national
standards in a slavish or unthinking manner.
4. The Guidance should highlight the importance
of planning for sport, open space and recreation and the need
to provide sufficient resources for local research and needs assessment.
It is no less important than planning for transport, housing,
employment or any other arena.
5. Paragraph 36 causes concern. It is likely
to give legitimacy to developers who might put forward proposals
to move existing sports clubs out of our towns and cities and
into the urban fringe or the green belt. This has previously been
experienced, notably in Bristol in the late 1980s/early 1990s.
It is regrettable that pressure might be brought to bear for relocation,
thus reducing the availability of local facilities. When relocation
outwards occurs, it is those who are less mobile who suffereg
children, the elderly, parents and carers with young children,
the unwaged and those without private transport.
6. On the question of "joined up"
government, a number of observations are made:
planners and asset managers in local
government must work together more effectively;
the DTLR and Sport England use a
different definition of a playing field/pitch to the DfES. This
confuses the public. It also means that on a statistical basis
like cannot be compared with like. It is a nonsense that different
definitions are used;
in "A Sporting Future for All",
the formation of a Playing Fields Monitoring Group was promised.
Comprising representatives of the DCMS, the DfES and the DTLR,
together with representatives of the NPFA, Sport England and the
Central Council of Physical Recreation, this group first met in
July 2000 and has met five times altogether. Its job was defined
as publishing "monthly figures on playing field disposals
so that progress can be accurately charted". Nothing has
yet been published, nearly 18 months after its formation. The
rate of progress is clearly not good enough and the NPFA has made
its concerns known to the Group and the Minister for Sport.