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
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
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