Memorandum by Kit Campbell Associates
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.
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
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 thensuch as floodlit or artificial
pitchesare 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
populationto 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
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, Harrogatea Council which has been "capped"
for the past eight or nine yearsproposed 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
investmentmade possible by some Lottery funding programmes
and the "bidding culture" in which local authorities
have to operatebecomes 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
What is needed to overcome these problems is:
Greater clarity in relation to desirable
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
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
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
Most planning authorities have adopted very
simple provision standards. However, the "decision tree"
approach above indicates that they should include at least:
A quantity standardthe 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 thresholdthe distance
that typical users are willing to travel to each type of open
space. Distance thresholds should also be locally determined.
A quality standarda 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 multipliermost
sports facilities and children's play areas require a site area
significantly larger than the actual facility.
Normalised capital, establishment
and maintenance coststo be used when assessing either Section
106 contributions or commuted maintenance sums.
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
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, orat least for
outdoor sport and recreation facilities such as pitchesa
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 itand 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?