Examination of Witnesses (Questions 280
TUESDAY 30 OCTOBER 2001
280. Those figures go back to 1938. In 1938
most children could pretty safely play in the street outside their
house. There must have been a huge amount of football and cricket
played in the streets. Very few streets are now safe for children
to play in. Should not the figures take into account what you
have just said?
(Mr Garber) Could I possibly deal with this in two
parts, then if Don Earley could follow on. Yes, you can go back
to 1938, but there was a clear change in what is on our streets
now. The level of car ownership is significantly greater and the
speed of vehicles has changed, and that has changed what is available.
Nevertheless, within those strategies the NPFA introduced a very
clear guidance in 1992, where opportunities would exist within
urban areas and within streets by facilitating through design
areas of play that could meet a safe area of activity within those;
by traffic calming measures being introduced; by small areas of
activity that could be controlled and contained relating to a
pedestrian way; where speed of vehicles moving through those areas
were functional. Indeed, this follows on from a system called
Woonerf in Holland, which was an area very much involved in the
involving of such areas where there was a clear linkage between
use, activity and movement.
281. That sounds all right, but I cannot think
of any streets in Denton and Reddish that have been made safe
as a result of things like that.
(Mr Earley) The indications in the work that has been
undertaken by Oxford Brookes of the NPFA Standard may be on the
low side, and in certain areas it should be higher. I think that
is probably a matter for the planning authorities once they have
undertaken their local investigations. We mentioned the possible
increase in participation of urban areas because of more modern
facilities. The Six Acre Standard is a normative standard which
gives a degree of consistency, I think, which is helpful for planning
authorities and to developers alike. In the detail it could be
282. But we have the same Six Acre Standard
for areas as diverse as Shetland, the Isle of Wight and the West
Midlands. Is that not a nonsense?
(Mr Earley) I do not think I would agree that it is
a nonsense. First and foremost, I would like to differentiate
between children, play and adults. I think it is very arguable
that the needs of children, wherever they are, are universal.
There is a need for children to be able to play safely out of
doors, outside of the home and garden, and it does not matter
where it is.
283. Some children have a huge rural hinterland
and some have narrow streets.
(Mr Earley) A huge rural hinterland is not always
available for them to take advantage of in terms of being able
to play freely and safely. There are dangers in rural hinterlands
in the same way there are dangers in the open streets. I do think
the case is there and it is arguable. In the 1989 edition of the
Six Acre Standard that debate was entered into and discussed.
When we come on to matters to do with provision of outdoor land
for sport the point that you make is a sound one. There we would
again turn to the fact that local assessments need to be undertaken.
We would advise a three-pronged approach quite simply for outdoor
sport: the first is the Six Acre Standard, or a standard determined
locally per thousand population for the land overall; the second
would be so many pitches for, say, football, cricket, hockey or
netball per thousand population; and the third one would be an
assessment of supply and demand for facilities and space for those
different activities. If you take one of thoseif you take
the Six Acre Standard aloneyou are likely to end up with
a far more inaccurate position than if you try all three. What
we would urge is that planning authorities actually try all three.
284. It sounds as if football is the guidance
essentially rather than some sort of very fixed rigid rule. That
would obviously make it more difficult for local authorities to
formulate their own local standards, would it not?
(Mr Garber) I do not think that is the case. First
of all, I think it is crucial that there is an overall standard.
It is no different in terms of the content within PPG17 and the
reference there to the way in which one would look at uniformity
of guidance with reference to parking. There are two aspects:
first of all, I think it is important that there is an overall
requirement and an overall standard by which every community can
measure a need; and, where there is going to be provision, where
that measure can be quantified. Secondly, it does not preclude
authorities indicating and assessing any deficiencies. It is deficiencies
that then can be addressed again through the planning process
by reference to the justification through Circular 1/97 as to
whether there are other needs that need to be addressed. The importance
of conformity on a national basis is crucial, but the deficiencies
still have to be addressed within the local authorities; and the
way in which they address them has to be both quantified through
their own needs and also assessed as to how they will meet that
285. You are not against the formulation of
local standards, but you would expect them to be consistent with
(Mr Garber) I am not in favour of local standardsto
the extent that I believe it is crucial that there is a general
conformity to a national standard. What I am not removing is the
importance of local authorities identifying shortfalls in provisions
and finding mechanisms of how those shortfalls and provisions
are made. That can be achieved through a number of wayswhether
through a development process, where it can be justified against
the background of genuine planning gain. You have to find ways
of redressing the deficiencies but, in the first instance, it
is quite inappropriate that one should be looking at markers which
for one part of the country (because of a local agenda) should
be in one area, against another area where they say, "We
don't need that; we think there's enough". I think the actual
control through a mechanism of an NPFA Standardwhich has
stood the test of time, and stood a very big test over the last
ten years where inclusion in policies has been fundamental to
the success of achieving standards within authorities and the
fact they have to comply through the development process of section
54(a) of the Planning Actmeans that there is a clear foundation
and justification for a clear national planning standard.
286. Is there not a weakness in the standard
, because it is purely a quantitative standard and not a qualitative
standard? Do you think PPG17 could do any better?
(Mr Earley) I think it is incorrect to suggest that
the NPFA Standard is a quantitative standard. If you go back to
when it was first published
287. It is incorrect. It does not say anything
about the quality of the playing fields but the amount of playing
fields per head of population. That is a quantitative standard,
is it not?
(Mr Earley) No, I do not agree with you.
288. I do not know what a quantitative standard
(Mr Earley) There is a quantitative standard, but
if you look in the body of the Six Acre Standard, in the present
one as published in the appendices or in the new one which I have
not made available to the Clerk yet, if we are talking about playing
fields we talk about issues to do with drainage, gradient, orientation,
and a whole range of issues which bear upon the quality of those
289. Those bits get forgotten, do they not?
(Mr Earley) They may get forgotten. I would willingly
acknowledge that in the past the NPFA has probably done the cause
and itself a little disservice by putting them in as appendices;
but now they will be brought forward into the body of the text.
My colleague, Mr Garber, may want to elaborate, but the same applies
in terms of what we say about children's access and needs.
290. A local authority might fail on your standard
because they presented very, very high quality playing areas but
simply not enough; and another local authority would pass on your
Standard by producing acres of scrubland, almost unusable?
(Mr Earley) Again, I do not agree. In the introduction
I think we talked about outdoor playing space, whether it be for
recreation generally, sport or play, as being land suitable for
its intended purpose, size and nature. Having said all that, there
may be a tendency to look superficially at the quantitative issues
that we are talking about and not recognise the importance of
quality of facilities locally for people.
(Mr Garber) Could I just expand on that. One of the
key issues that was addressed in 1992, and has been expanded on
in the current document, was the importance not just of looking
at the quantitative factor but, more significantly, of the qualitative
factor. We were looking at the movement of young children and
youths from their homes to the area of activity. When you look
at that in terms of location of dwellings to the location of the
facility, the walking or cycling time, depending on sustainability
and ensuring that those provisions are made on a dimensional basis
both in radial terms but also a factual walking time of minutes,
that related specifically to age groups. We categorised and tested
this with young children and, looking at gradients, you actually
ensure that the qualitative factor comes into it. While the quantitative
considerations remain and you are looking at it overall, what
we are ensuring it is that the provision is in the right place
to meet the needs of those who need to use those spaces.
291. You have defended yourselves very successfully,
but how far does PPG17, as proposed, carry your defence forward?
(Mr Earley) Could I make a general remark first and
foremost. I think PPG17 is not helpful enough, because it is not
only the Six Acre Standard but the recommendations that came originally
from the GLC and then promoted by LPAC that were referred to in
the evidence given by the lady from the Greater London Authority
last week. There are also recommendations made in terms of accessibility
to open space by English Nature. It seems to me what PPG17 should
be doing is to make clear reference to the work of other organisations
where it is considered to be appropriate; to underline the strengths;
if need be to make one or two comments about reservations; but
to give clear reference to a bibliography, which is not there
at the present time; and, as it did previously, to give illustrative
examples which it did before. What is needed is, I think, a clearer
framework for planning authorities, developers, the community,
everybody so that they can make their own judgments about issues
for the future. I think that is what we would like to see as the
National Playing Fields Association.
(Mr Garber) The weight of that is, within local plans
(which are in a sense the generators of what comes forward) is
a general background/documentation by reference to PPG17; but
the actual policy is that that ensures deliverability of the facilities
are very much set against the NPFA Standards; and it is important
having that direct correlation between the standards, policies
and strategies of the NPFA linked through to PPG17 that will give
weight. The weight then follows through to the planning process
and the need for compliance with local plans, structure plans
and the like.
292. How can we deal with the issue of maintaining
facilities, particularly children's play areas?
(Mr Garber) Historically I think there have been problems,
and I will come back to that in a moment. It may be helpful just
to give the background. Apart from my role with the NPFA, I am
Planning Director of Britain's leading house builder, so I do
have a direct understanding of the problems and the application
of overcoming those problems. Currently one has to assess where
new provision is made, particularly if it is relating to developments,
that first of all you meet the standard that is set out in terms
of play provision and recreation provision. The local authorities
quantify through maintenance costs what is required to ensure
that maintenance is going to be delivered over a 10-15 year period,
whatever satisfies them. The multiplier is projected, it is indexed-linked,
and developers are required to pay an appropriate commuted sum
secured by planning agreement into the authorities. While I have
no issue that it should go into a wider fund and get maximum interest
benefits, what is crucial (because every single space is different)
is whether topographical considerations are there to be conserved,
the proximity of closeness to footpaths, whether it is cycleways,
whatever it may be, every one is differenttherefore the
calculation for maintenance for commuted payments is different
in each case. What is essential in my view is that there must
be a commitment to ensure that there is a dedication of those
funds relating to those spaces. What happened historically, and
we are living in a legacy where spaces have not been maintained,
or there are particular problems with local authorities in maintaining,
is that there was a fund that was provided but it was not dedicated
or committed to the maintenance of the specific spaces and it
dwindled away. At the end of the day you have problems with maintenance.
I think the other point which comes in which is against the historic
provisions, against what is not applied (and this goes back to
the answer I gave to Dr Pugh), we now look at qualitative space
in the right location in its proximity to dwellings. No longer
do you find spaces that are stuck around the corner, that are
hidden and have no function and are not supervised, where parents
will have concerns. You have the functional space, you have the
quality provision, you have the quality in terms of the technology
that goes into the surface materials, and the safety of equipment
that goes in there, and you have the modern technology in terms
of the limitations that one now has to consider in terms of the
needs and demands for maintenance. Those, I believe, have positively
been addressed. It is something that has emerged but I understand
and appreciate that historically there has been a problem.
293. How specifically can the responsibility
for the ongoing maintenance of, for example, children's play areas
be written into planning approvals?
(Mr Garber) There are two factors: first of all, it
is now common (and I say this from dealing with matters all over
the country) for local authorities to seek commuted payments for
the maintenance of play areas. They would range in terms of the
quantification of between 10-15 years with interest, and that
goes into the sinking fund which then provides for the ongoing
management beyond the 15 year period. It is happening and it is,
I think, universally happening throughout the country. It certainly
was not happening but the way it is addressed now it is. It is
a requirement and it is very much a standard requirement through
the policies of local plans which set up in specific terms that
developers will enter into an agreement related to a particular
site to ensure that provision is made.
294. Why then do we have so many examples of
play areas which are either not maintained or in fact cease to
be equipped because of maintenance issues?
(Mr Garber) This goes back to the historical point
where, unfortunately, commuted payments were not dedicated to
the specific areas. That is not happening. It was a fund it was
put in. There was no real examination as to the costs as to what
was required. Authorities are very much more alert to what is
now required, and I think justifiably so. They will look at a)
the type of equipment, the type of surface, and they will look,
through experience, at how frequently it has to be replaced, how
frequently it has to be managed, how frequently it has to be upgraded.
Historically it was not there. It is an ongoing problem. What
one has to look at, clearly, is where enhancement can take place
within new developments; where they are in proximity to older
facilities that you ensure that the right provision is there meeting
that requirement and to manage it and maintain it. This issue
of meeting the needs of the community has to be seen as a legacy
that is going to be ongoing, rather than a matter that has been
forgotten. It is the forgotten areas, I agree, that need to be
295. How many local authorities meet your minimum
standards for equipped children's' play areas?
(Mr Garber) I think since 1992I think it goes
back far more than thatthe very fact that in 1992 it was
not just an NPFA guidance dealing with outdoor play spaces, it
was a design guide which set up in practice how that provision
should be met. Certainly from my own experience, on both sides,
it is now a provision that is being required.
296. You were asked how many actually meet the
(Mr Garber) I would find it impossible personally
to answer if one is looking at quantification over the years.
297. How many now?
(Mr Garber) In the last ten years, where there has
been an obligation to meet those requirements that has been met.
298. Are you saying at the moment all local
authorities meet your minimum requirements?
(Mr Earley) I think what we have to say and acknowledge
is that there has been no research across the board into how many
local authorities in the whole of their areas of administration
meet the NPFA's Six Acre Standard. What Paul has been saying quite
clearly is that, where there have been new developments a great
deal of those developments in recent years have conformed to the
recommendations of the NPFA; but they are not necessarily going
to be able to meet any deficits that were there before. Having
said that, I am not in a position to give examples to you.
299. Mr Garber, you mentioned briefly your own
role as somebody who works in the development business and also
your role in the NPFA. To what degree do you think the objectives
of the two different groups are the same, or are they different?
(Mr Garber) I think they are the same. Any house company,
in my opinion, is creating communities for the future and it is
their responsibility to provide the facilities and the environment
for future occupiers. That is the legacy that is expected and
should be expected. The concerns that are now addressed, quite
rightly so, are to ensure that those provisions have a quality
in terms of the type of facility that is there, and a legacy which
any developer worth their salt should ensure is met. I do not
see a conflict. I know the HBF have been here. The HBF have been
involved with the NPFA in the new guidance in a positive role.
The fact that you have the industry which I am involved in fully
supporting the objectives and the aims that the NPFA are now trying
to achieve I think is testament to what is the commonality between