National Planning Policy Framework

Written evidence from Fields in Trust

Summary

· FIT’s core work is the provision, improvement and protection of outdoor space and facilities for sport, play and recreation and this provides the focus for our evidence

· The Government’s objectives of promoting sustainable development for economic growth, and streamlining and clarifying planning policy are supported by FIT, though FIT considers more detailed guidance is needed when planning for sport, play and recreation

· Our strong recommendation is that the Government endorses FIT’s guidance in ‘Planning and Design for Outdoor Sport and Play’ (2008) as good practice guidance to which regard should be had when planning for sport, play and recreation

· Planning for sport, play and recreation should be afforded more weight, and further clarification should be provided by the Government about how the presumption in favour of sustainable development will work in practice, otherwise the fear is that previous protection under PPG17 for policies for outdoor sport, play and recreation will be eroded

· The current policy in PPG17 relating to the provision of like for like replacement land in place of open space to be developed should be reinstated

Background to Fields in Trust

1 FIT is the operating name of the National Playing Fields Association. FIT’s work is to ensure adequate provision of, and protect and improve, outdoor facilities for sport, recreation and play. FIT does this directly and indirectly. Directly, FIT has a legal interest in 1281 sites throughout the United Kingdom comprising in total 8804 acres (3563 hectares) of land, over which it has secured contractual rights, protecting them for recreation and requiring its specific consent in advance of any disposal, consent granted only if betterment is agreed in terms of replacement facilities. These figures are set to increase significantly under FIT’s current land protection initiative, the Queen Elizabeth II Fields Challenge. 637 nominations, covering a further 9786 acres (3960 hectares) have been received to date.

Indirectly, FIT has been making recommendations on planning for outdoor recreational facilities to local authorities, developers and the community at large, since its formation in 1925. These recommendations, formerly known as the ‘Six Acre Standard’, are now published in ‘Planning and Design for Outdoor Sport and Play’ (2008). Covering aspects of provision involving quality, quantity and accessibility, these recommendations serve as benchmark standards, and are either referred to, adopted or used by some 70% of local planning authorities throughout England (and the United Kingdom as a whole) as a tool in the Local Plan process. They therefore constitute objective and respected industry-standard practice guidance of the type we understand the Government seeks to encourage from appropriate third parties.

The Basis of FIT’s Evidence

2 This response is concerned with the planning system so far as it relates to FIT’s work as described above. It focuses upon policies relating to the adequacy and quality of facilities for outdoor sport, play and recreation, and their protection, in the broader context of open space, in particular by consideration of predecessor policies as stated in PPG17. These policies, including the need for sport, play and recreation in new developments, impact upon strategic planning nationally and locally.

3 FIT responds below to the questions asked by the Select Committee as follows:

Question 1: Does the NPPF give sufficient guidance to local planning authorities, the Planning Inspectorate and others, including investors and developers, while at the same time giving local communities sufficient power over planning decisions.

4 FIT supports the Government’s key objectives of simplifying and clarifying the planning system, and within that framework of underlining the need for sustainable development and encouraging the involvement of individuals and communities in planning. Part of that commitment is reflected in the distillation of national planning policy into a single document, the NPPF.

5 Guidance on our area of work was previously given in PPG17 on Open Space, Sport and Recreation (2002) and its Companion Document. PPG17 was 15 pages long. The relevant section in the draft NPPF is now only 1 page long, comprising 5 paragraphs. It is absolutely correct that the NPPF should be more accurate, brief and concise than its predecessor but its content leads to a huge reduction in the availability of worthwhile guidance to planning authorities and developers alike. The impact that this will have upon quality and consistency, quality and speed of delivery of development management and the appeal system could be considerable, and possibly adverse, if something were not done to fill the gap this creates.

6 We therefore recommend that more detailed supporting information should be made available to all involved in the planning system. As we have said above the most respected and used document in the context of outdoor land and facilities for sport, play and recreation, including playing fields, is FIT’s ‘Planning and Design for Outdoor Sport and Play’ (aka ‘The Six Acre Standard’). The stated recommendations cover quantity, quality and accessibility of space. They present benchmark standards which assist in the development of local standards of provision as advocated by the Government. They are not national standards to be slavishly adhered to but they are tried and tested and are referred to, used or adapted by some 70% of local authorities in the planning process.

Our strong recommendation is that the Government endorses FIT’s guidance as good practice guidance to which regard should be had when planning for sport, play and recreation space.

Is the definition of sustainable development contained in the document appropriate; and is the presumption in favour of sustainable development a balanced and workable approach?

7 As mentioned in paragraph 62, the planning system is plan-led. Local and Neighbourhood Plans therefore should lie at the core of that system, providing its infrastructure and nerve-centre. The principle of sustainable development, supported by FIT, therefore contributes significantly to the process of Plan development and, inter alia, the enhancement of an individual’s and communities’ quality of life, health and welfare through outdoor sport, recreation and play. Open space and facilities for these activities should be afforded greater consideration, prominence and protection than currently indicated.

8 There has been much discussion in the media of late about the impact of the presumption on favour of sustainable development. FIT sees the merits of such a presumption but given that the Government has stated that the planning system is plan-led and that in paragraph 10 it defines sustainable development in the context of planning for people, places and prosperity, it would be logical and desirable for a clarification to be provided which incorporates the following:

· The planning system is plan-led and incorporates the principle of sustainable development

· This places an emphasis on planning for people, places and prosperity with weight afforded to each dependent upon the nature of policy, or in management development terms the nature of any proposal

· These considerations are set within recognition of the importance of growth and housing to the community at large and country as a whole

8 Such a statement will help create an improved balance within the system while also ensuring that issues relating to open space are given fair and proper consideration and objectives relating to prosperity, development and housing can be met.

9 FIT also considers that the way in which the presumption will operate is insufficiently explained. FIT’s particular concern is that the interface between economic, social and environmental considerations needs to be better explained. If, for example, development clearly achieves economic and social advantages but at the expense of environmental factors then is the presumption engaged? Historically areas of recreation space properly enjoyed protection from development through the policies in PPG17. Without clarification of how the presumption will work in practice FIT considers there is a real risk that this protection will be eroded to the detriment of play space provision.

Are the core planning principles clearly stated and expressed?

10 Paragraph 19 refers to the planning system being genuinely plan led, which is a fundamentally positive and beneficial principle. Statements including the need for a proactive drive towards development and the importance of planning decisions being made in the context of local circumstances are equally clear.

11 Reference is also made to the multi-functionality in both urban and rural areas, of open space, including recreation, and to the need for local strategies to improve health and well being. These statements are clear and fully supported by FIT.

Is the relationship between the NPPF and other national statements of planning-related policy sufficiently clear?

12 FIT has no comment to make on this, apart from the observation that as drafted the NPPF, if so confirmed, would tend to weaken existing policies about protection of land and facilities for outdoor sport, play and recreation in PPG17Does the NPPF serve to integrate national planning policy across Government Departments?

13 It is too early to draw a conclusion and FIT therefore has no comment to make.

Are the policies contained in the NPPF sufficiently evidence based?

14 In the context of open space and outdoor sport and recreation the answer is, unfortunately ‘no’.

15 There is a need for strong and robust evidence on these matters and the NPPF must call for it. Insufficient reference will, it is predicted, reduce the weight accorded to this essential aspect of planning and lead to decisions in favour of built development, predictably to the detriment of individual health and quality of life, and community cohesion and well-being.

16 The following are brought to the Select Committee’s attention:

· Paragraph 23 on plan making should include reference to open space and leisure facilities

· Paragraph 24 should be amended to include reference to open spaces and facilities being protected

· Paragraph 27 should include specific reference to assessment and strategies for open space, playing fields and leisure

· Paragraph 38 should include specific reference to information on open space, playing fields and leisure in the context of health and well-being

· Accordingly paragraph 128 should be strengthened and again refer to robust assessments of need, as stated in current policy

· Furthermore, the statement in paragraph 129 that ‘Existing open space, buildings or land, including playing fields, should not be built upon unless …… the need and benefits of the development clearly outweigh the loss’ undermines the process of evidence gathering as the key information for policy determination in the context of the future of open spaces.

· FIT would however wish to see a policy incorporated enabling development where loss of facilities is compensated by (at least) like for like facilities being provided

16 By way of explanation, in the context of plan making, strategic priorities are referred to in paragraph 23. There is a need to include open space and leisure facilities for sport, play and recreation, and their development. Similarly, paragraph 27 calls for up to date Local Plans, based on relevant evidence. Up to date open space and playing pitch strategies (ie adopted within the preceding three years) have ot been a priority for many local authorities and consequently many authorities have not been able to use up to date information as the basis of local policies and standards. To help overcome this, specific reference should be made to their need in paragraph 27. This could be reinforced by including reference to such facilities within paragraph 38 in the context of their contribution to health and well-being.

17 FIT ha a serious concern about the lack of credible, up to date assessments of open space, including playing fields. Too many local authorities have failed in this respect. The danger is that in the absence of such assessments permission for development will be granted with the encouragement of the NPPF. However, once built upon open land is lost forever (except in the rarest circumstances). Development by virtue of default is unwelcome. Government needs to make clear that evidence gathering is of key importance, and that failure to do such work by planning authorities shall not be condoned. Appropriate penalties should therefore be identified and implemented, as opposed to such failures ‘clearing the way’ for planning permissions. A proportionate stick is needed to ensure that recalcitrant authorities mend their ways, not a carrot to encourage development by default.

Conclusion

17 FIT welcomes the publication of the draft NPPF and its objectives in relation to simplifying and clarifying the business of planning policy. As currently drafted, however, the NPPF disadvantages outdoor open space and facilities used for sport, play and recreation. As a result there is danger that open space, including playing fields will be in greater danger from development without adequate replacement or compensation and, consequently, overall provision will be inadequate in terms of quantity, quality or accessibility.

Fields in Trust

September 2011