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Response to Consultation on Scottish Planning Policy 11: Physical Activity and Open Space

Introduction

1 The National Playing Fields Association (‘NPFA') is a UK wide organisation concerned with the improving the quality of life and health of all members of society, by assisting in the provision, improvement and protection of high quality, well used facilities for outdoor sport and play throughout the nation. To this end the NPFA protects some 1150 sites covering over 8000 acres around the UK. The NPFA in Scotland also works closely with the Scottish Executive and Parliament, and with the unitary authorities on matters relating to facility protection and improvement, including the development of planning policy and appropriate use of the planning system.

2 By way of summary, the draft is considered to be both competent and comprehensive. It is very much welcomed by NPFA Scotland, and we recognise the commitment of the Scottish Executive to protecting and enhancing the country's green space heritage and providing new, accessible, high quality facilities and opportunities for sport, play and other forms of physical activity, particularly at the local level. The publication of SPP11 for consultation is general evidence of that commitment. The proposed national minimum open space standards for new development serve as a specific example of that commitment.

3 NPFA Scotland is pleased to note the reference to its role in the Appendix referring to Consultees and Stakeholders.

The value of physical activity and open space (paragraphs 9-12)

4 A clear exposition is provided of the diverse benefits that arise from the use of open space and sporting facilities. These include improvements to the quality of life, enhanced environments and visual amenity, mental health and relaxation, the economic benefits of quality place making and regeneration, improved biodiversity and accessible educational resources. But rightly, in our view, bearing in mind the health issues facing Scotland, paramount position and consideration is given to physical activity and open space within SPP11 as drafted.

5 Paragraph 8 specifically refers to rural areas, mainly in the context of the variety of natural settings, and the role of rural areas and the countryside in terms of travel, visits and tourism and access to the national heritage. In the context of this introduction, however, NPFA Scotland recommends that reference is also made to the needs of rural communities to have access to quality facilities for sport, play and open space uses at the local level.

Policy Context (paragraphs 9-12)

6 NPFA Scotland welcomes the reference to the Scottish Executive's strategy for physical activity. We would suggest that that in terms of master planning for new developments, the principles of active design are incorporated. Active design promotes development that maximises opportunities for participation in sport and physical activity. It is concerned with improving accessibility, enhancing amenity and increasing awareness, and emphasises active travel (walking, cycling), co-location, formal sports and leisure provision and informal activity and recreation.

7 NPFA Scotland also strongly recommends that given the widely recognised role of play in the development of children, specific reference is made to the needs of children and young people for play, sport and other forms of physical activity, both formal and informal.

Objectives (paragraphs 13-19)

8 NPFA Scotland supports the key objectives but urges inclusion of suitable reference to accessible opportunities to play, sport and other forms of physical recreation for children and young people, both formal and informal.

9 This could be achieved, for example, by re-writing the first and last objectives as:

• To ensure local authorities take a strategic approach to sport, play and open space provision
• To provide guidance on planning for development of new sports, play and recreation facilities.

Quality, quantity and accessibility (paragraphs 20-21)

10 NPFA Scotland supports the need for standards which deal with quantity, quality and accessibility. This approach has been increasingly incorporated into recent revisions of our own Six Acre Standard (‘6AS'), notably in 1992 and 2002. As we state elsewhere, we welcome the proposals for minimum standards of provision for open space in new developments. But we also urge the Executive to consider the provision of specific space for children's play and recreation, both informal and informal. The 6AS typology of local areas for play, local equipped areas for play and neighbourhood equipped areas for play would provide a sound basis for contributing towards the development of an open space a typology, dealing as it does with play provision as a fundamental part of active design and management issues such as types of provision, cost of maintenance, public safety and minimisation of potential nuisance.

11 NPFA Scotland also recommends reference to facilities being fit for purpose. The recent Sport Scotland audit of sports pitches made somewhat grim reading. While quality is difficult to define in a consistent way across the country, the inadequate drainage and grass condition, and the state of ancillary changing and other facilities, clearly require a consideration as to whether the facilities are indeed ‘fit for purpose' if they are to contribute in a meaningful way to an audit of available facilities.

Open Space Audits and Strategies (paragraphs 22-27)

12 NPFA Scotland supports the need for local audits and assessments of all forms of open space. We share the view of the Executive about the variable degree to which audits and strategies have been prepared across the country. Despite advice given in NPPG11, published 10 years ago, and PAN 65, published 3 years ago, too many Scottish local authorities have, to date, failed to complete the process.

13 It is evident, therefore, that planning for open space generally and sport and children's play specifically, has all too often been the poor relation of land use planning and the development plan system. The malaise should be treated so that such audits and strategies are a required and integral part of the development plan process

14 In terms of timing the following are recommended:

• Open space audits and strategies to be completed within two years of the date of publication of SPP11
• Audits to be updated on an annual basis, as is the case with the Active Places database in England.

Protecting of open space and presumption against development (paragraphs 28-35)

15 The presumption against the development of existing valued and functional open space and open space capable of being brought back into use is fully endorsed. NPFA Scotland's position is that before alternative built development is considered due assessment and consideration should be given to all forms of open space identified within the PAN 65 typology.

16 However, the NPFA is concerned about the reporting of planning applications on playing fields. Sport Scotland's annual report is misleading. It does not include areas of playing fields that surround playing pitches. It claims there is no loss when pitches are simply relocated to existing publicly accessible green space, with the original site lost to development. SPP11 should exclude such possibilities.

17 Sport Scotland is a statutory consultee on applications for development of playing fields, but there is no similar statutory consultee(s) covering all other forms of open space. Sport Scotland's role is clearly constrained and the consultation process, by virtue of the definitions used, myopic. A system is required that examines applications for the development of all forms of open space on a statutory consultee basis. The NPFA could play a positive role in this alongside other partners such as Play Scotland.

18 Otherwise the NPFA welcomes very much the measures identified in paragraph 32 for protecting playing fields and notes that they provide a better basis for that purpose than the equivalent policy guidance given in either England or Wales. The NPFA also acknowledges and supports paragraph 35 and its potential importance in protecting smaller areas used for sport.

Local authority development and schools development (paragraphs 36-39)

19 Some schools planned for construction do not meet the terms of the current Schools Premises Regulations (last published in 1967). Two recommendations are made:

• The Regulations should be revised and incorporated as minimum requirements for open space at schools within a future version of SPP11
• Specific educational legislation should be introduced to protect school playing fields by reference to criteria governing present and future schools' use, present and future community use and the application of proceeds. Parallel legislation exists in England and NPFA Scotland is, among others, able to advise.

20 NPFA Scotland supports the provision of all weather pitches in school and community settings, provided at least one grass pitch exists on the site concerned, if it is an existing playing field or sports facility.

21 In regard to provision in local authority and school developments, NPFA Scotland supports the provision of multiple use open spaces and facilities where appropriate, though some forms of provision such as children's playgrounds may need to be dedicated facilities. We would express caution about educational facilities acting as a community focal point or hub. While this may work, community use depends very much on the goodwill of school governors and staff and access to and use of facilities. Situations may change quickly and detrimentally. Formal community use agreements are therefore necessary.

Design of open space (paragraphs 40-41)

22 Open spaces should contribute to settlements based on the principles such as active design, multi-functionality where appropriate, fitness for purpose, attractiveness, value for money from a capital investment and maintenance perspective, and sustainability over the long term.cater for people of all ages.

Minimum standards (paragraphs 42-44)

23 NPFA Scotland supports the proposals for minimum standards for the quantity of open space that should be included for different types of new development. The NPFA notes that local authorities are directed to develop their own accessibility and quality criteria. Our experience is, however, that guidance is needed and we recommend our own Six Acre Standard in this respect, along with any other publications which the Executive feels would be helpful. This does not reject the need for local standards but gives options for tried and tested methodologies.

24 As a general principle, open space should only include open space which is publicly accessible. This is very important when audits are being undertaken and strategies developed. So, for example, school playing fields need to be available for seasonal letting if they are to be included in open space audits.

Management and maintenance (paragraphs 45-47)

25 NPFA Scotland supports the need for planning agreements to be reached in developments, with conditions attached to planning consent covering management and maintenance requirements, together with their funding by the developers for a minimum period of 15 years. Arrangements for the long-term protection of the open space, by way of legal contract, should also be entered into guaranteeing continued use as open space, public accessibility and disposal only in the event of betterment and the reapplication of all proceeds to open space provision. Again, the NPFA is able to advise.

Planning for new facilities for sport and recreation (paragraphs 48-49)

26 An additional paragraph is recommended on provision for children and young people. This should deal with the need for a variety of provision in dedicated and non-dedicated settings. It should recognise and recommend the importance of consultation generally with local communities and, most importantly, specifically with children and young people. NPFA Scotland strongly recommends that the need for casual play space, based on multifunctional open spaces, in housing developments is included alongside dedicated provision.

Development management considerations (paragraphs 50-52)

27 The key importance of location is recognised here and supported by NPFA Scotland, as are the principles of Active Design already referred to. While we would also support the statement that certain forms of sport and recreation provision may be best located on the edge of settlements, we emphasise the importance of local provision for play, sport and recreation, accessible by walking or cycling. The health needs of the less mobile must not be disadvantaged by the centralised location of facilities or the creation of, for example, destination or visit playgrounds at the expense of local opportunities for activity. By less mobile, NPFA Scotland refers to those such as children and young people, parents or others with babies and toddlers, the elderly, the disabled, the unwaged/unemployed and those without their own private transport, particularly where public transport is either non existent or infrequent.

Stadia (paragraphs 53-54)

28 We have no comment to make.

Outdoor access and recreation (paragraphs 55-60)

29 NPFA Scotland recognises the importance of green networks in urban areas, the contribution of regional, country and national parks, and nature reserves and coastal environments and the rights of access of the public to such facilities and environments.

Further Contact

30 Please get in touch with:

Colin Rennie
Development Officer, NPFA Scotland
01382817427
07766 656856
colin.rennie@npfa.org

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