Memorandum by City of York Council (PPG
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
2. THE CONTRIBUTION
REVISED PPG TO
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
meansis 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
PPG TO THE
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
PPG IS SUCCESSFUL
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
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
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
PPG TO ACHIEVING
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.