Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by The Royal Town Planning Institute (PPG 18)


  1.  The Urban Affairs Sub-Committee of the House of Commons Select Committee on Transport, Local Government and the Regions has resolved to undertake an inquiry into the draft revision of Planning Policy Guidance Note 17 "Sport, Open Space and Recreation", issued for consultation by the then Department of the Environment, Transport and the Regions in March. The Sub-Committee is particularly interested in:

    —  the contribution of the revised PPG to strategic planning for sport, open space and recreation;

    —  the contribution of the PPG to the provision of high quality new open space and sports opportunities;

    —  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 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; and

    —  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.

  2.  In June, the Institute submitted to the Department for Transport, Local Government and the Regions a memorandum of observations on the consultation draft. As this will be made available to the Sub-Committee's inquiry, consequently, the content of that memorandum is not repeated here unless directly relevant to the Institute's comments on the specific issues that the Sub-Committee has indicated it wishes to consider.

  3.  After some general comments, this submission addresses, from the Institute's viewpoint, the five specific issues raised by the Sub-Committee.


  4.  The Institute generally welcomed the consultation draft of the reviewed PPG 17. Updating and revision of policy in this area was overdue, following the extensive review of mainstream planning policy that has taken place since the existing version of the PPG was published in 1991, and the parallel changes in the Government's attitude to, involvement in, and support for, sport.

  5.  The Institute supports the inclusion in the draft of guidance on the provision and retention of open space, alongside that on sport and recreation. There are, however, weaknesses and inconsistencies, some of which are highlighted by the questions the Sub-Committee is posing in this inquiry.

  6.  In order to put later comments in context, it should be noted that the draft PPG sets its own remit by describing "the Government's main planning objectives for sport and recreation". Alongside a firm commitment "to protecting playing fields which are used by schools or the wider community", these are to:

    —  promote more sustainable patterns of development by creating and maintaining networks of recreational facilities and open spaces, particularly within our urban areas;

    —  promote social inclusion, health and well-being by ensuring that everyone has easy access to good quality sport and recreation facilities and open space; and

    —  support an urban renaissance, by making our towns and cities more attractive places in which people will choose to live.

  7.  Each of these objectives—sustainability, social inclusion, and the urban renaissance—is central to the Sub-Committee's inquiry. However, the draft PPG's guidance to local planning authorities (LPAs) on how they might be achieved is less than impressive. The advice (quoted below) is too all-embracing and too much like "motherhood and apple pie" to be convincing. LPAs are advised:

    —  to adopt a strategic approach and plan positively for the provision and enhancement of well-designed recreational and sporting facilities and open spaces;

    —  to provide the strongest protection for open space that is, or has the potential to be, of value to the community;

    —  to resist development pressures which could diminish recreational provision;

    —  to ensure that sport and recreation facilities are easily accessible by a choice of modes of transport and, where appropriate, are centrally located; and

    —  provide good quality open space and built recreation facilities as an integral part of new communities in order to make them attractive places to live.

  8.  There are some mixed messages—and some potential confusion as a consequence—in the draft PPG. For example, in the section starting with paragraph 27, a good case is made for the protection and retention of significant open spaces, but later the draft refers to the relocation of facilities to less sensitive and/or more accessible locations. In the right circumstances, both are desirable policy objectives, but not at the same time!


1.  The contribution of the revised PPG to strategic planning for sport, open space and recreation

  9.  Chapter 2 advocates a plan-led approach to the provision for sport, open space and recreation. That is no more than might be expected, but thereafter the draft PPG's contribution to planning at the strategic level is fairly superficial. No more than a single paragraph each is devoted to regional planning guidance (RPG) and structure plans.

  10.  Paragraph 8, on RPG, is too vague and generalised to offer any real guidance to regional planning bodies (RPBs). In particular, it presupposes that they will have knowledge of "the broad locational requirements or criteria for the national network centres in England which are to form part of the English Institute of Sport". The PPG is just the place where those criteria and requirements might be set out, by way of guidance and advice to RPBs—but they are not!

  11.  It is pleasing to see open space considered at all at the strategic level—and this is one of the instances where the draft remembers that it is supposed also to cover open space! However, it is difficult to identify a "strategic open space network" that might be of an appropriate scale to warrant consideration in RPG rather than in structure plans. Perhaps there are instances where such a network might cross the boundary from one structure plan area to another, but that must be fairly rare.

  12.  Paragraph 9 suggests structure plans (and UDP Part Is) should "contain the long term vision for their areas". While the Institute takes no great exception to this—there is no harm in sub-regional vision—it is normally regional planning guidance that is credited with "vision". That vision is then translated into successively greater detail in structure plans and local plans. Disappointingly, the guidance says little else on the role of structure plans.

  13.  In some contrast to the draft's treatment of more strategic issues, paragraphs 10 and 11 describe a realistic "plan-led" approach at the local level. In particular, they demonstrate the importance of a high level of consistency between development plans and the other plans and strategies of the local authority and its partners; the need for full public participation; and the positive role of supplementary planning guidance (SPG). There is, however a misleading reference, in paragraph 10, to the way in which sites of recreational value might be treated in local plan proposals maps that is at odds with the general advice on the issue given in PPG 12.

  14.  Chapter 4 of the draft PPG describes the essence of inter-authority working, and corporate working within local authorities, in the assessment of needs and planning of new facilities. Good planning will be aided by co-operation between local authorities, with other agencies, and with the private sector. The Institute has considerable reservations about the current availability of the information necessary to assess needs accurately, but this should not be allowed to deter joint working, and the establishment of appropriate monitoring systems. The latter should be part of regionally based plan monitoring arrangements using local indicators that can be aggregated easily, in order also to monitor change and progress at sub-regional and regional levels.

2.  The contribution of the PPG to the provision of high quality new open space and sports opportunities

  15.  The draft is generally satisfactory in its advice and guidance on the provision of new sports facilities, but less so in dealing with either the retention of existing or provision of new open spaces (see paragraph 11, above). Advice on locating new facilities is consistent with the sequential approach described in PPG 6 "Town Centres and Retail Developments"—an approach that is now well understood, and generally respected—and with the requirements of PPG 13 "Transport" in respect of green travel plans, levels of car parking, etc.

  16.  The real and potential contribution to new provision from the private sector is well recognised in the draft. However, a recurring difficulty in today's circumstances in not picked up in paragraphs 61-62. This is the identification of some formula for prioritising the developer contributions that might be made under planning agreements or obligations (section 106, et al). The range of potential contributions can be extremely wide, particularly in the case of a large mixed-use project—highway works, public transport support, affordable housing, etc, etc—and exceed what it is realistic to expect from a particular project. In these circumstances, how are the most appropriate contributions to be defined and selected? This is a rhetorical question about an issue yet to be addressed by the Government.

3.  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

  17.  This is one of the most disappointing areas of the draft PPG. It is difficult to be precise, or list paragraph references, but coverage is very uneven, with a marked inconsistency in the treatment of open space and informal recreation. Paragraphs 14-15 start encouragingly, but the promise is not maintained.

  18.  The whole topic area must be revisited before publication of the final version of the PPG, so that it can sit more comfortably alongside the guidance on the planning and provision of formal facilities.

4.  The extent to which the revised PPG's treatment of open space will contribute to the urban renaissance, the protections and improvement of open space and improved living environments

  19.  The Department claims, in the letter covering the draft PPG, that new planning guidance to help secure the provision and protection of sport and recreation facilities and open space is a valuable contribution to the urban renaissance and a better quality of life. More specifically, paragraph 2 of the draft states that "support for an urban renaissance, by making our towns and cities more attractive places in which people will choose to live" is one of the Government's main planning objectives for sport and recreation.

  20.  The Institute welcomes and supports the general treatise. However, the draft does little to demonstrate how the necessary linkages can be made, or strengthened, and tends to underplay the importance of informal open spaces in both environmental and social terms. The greatest disappointment with the draft PPG is its failure to deliver, in policy terms, what it sets out to achieve, especially with regard to open spaces.

  21.  An important plank of the urban renaissance (and of sustainable development) is the re-use of previously developed land. In pursuing this objective, and to counter risks of "town cramming", it is vital that policies for sports and recreation facilities, and for open space in particular, are presented with great clarity. Unfortunately, the draft PPG generally fails to do this. It would be more persuasive if it showed greater consistency in distinguishing between formal and informal facilities, and vigour in addressing the issues surrounding retention and provision of the urban greenspace that is important for recreation, but often vital for nature conservation and biodiversity.

  22.  Generally speaking, it is open spaces—both formal and informal—and not sports and recreation facilities that can contribute most to the urban renaissance and the quality of life in urban areas. Despite the title of the draft PPG, however, it often reads as though the inclusion of open space was an afterthought. It underplays the importance of informal open spaces both in environmental and in social terms.

5.  The contribution of the PPG to achieving the Government's aspirations on urban parks and play provision set out in the Urban White Paper

  23.  As suggested above, as presently drafted the PPG misses the opportunity to make a real impact on the urban renaissance. It is equally true, but probably less important, that the PPG will impact little on the Urban White Paper's aspirations for urban parks and play spaces. The PPG is concerned properly only with planning policy guidance, while the White Paper cast its net much wider. Irrespective of the draft PPG's treatment of the subject, where there are identifiable funding sources and implementation mechanisms, the White Paper's policies should be capable of being brought to fruition.


  24.  The consultation draft of the revised PPG should be generally welcomed as a positive step forward from the existing, which is now 10 years old. Nevertheless it contains some significant weaknesses that need to be addressed before the final version is released.

  25.  It appears less than convincing on a number of the specific issues to be addressed by the Sub-Committee's inquiry. In that context, the draft:

    —  makes little new contribution to strategic planning for sport, recreation and open space, but is much stronger in its guidance at the local planning level;

    —  deals adequately with the provision of new sports facilities, but is less convincing on informal recreation and open space;

    —  is disappointingly inconsistent, and often deficient in its guidance on the new subject area of open space;

    —  states, as a main objective, a contribution to the delivery of the urban renaissance, but fails to make the necessary linkages; and

    —  contributes little new to the Urban White Paper's aspirations in respect of urban parks and playspaces.

September 2001

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