Response to Consultation Draft Revision of TAN 16 Sport, Recreation and Open Space
Introduction
1 Fields In Trust (FIT) 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, FIT protects some 1150 sites covering over 8000 acres around the UK; 155 of these sites are in Wales. FIT Cymru also works closely with the Welsh Assembly and 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 comprehensive and competent. It represents a significant improvement on the existing guidance. It is helpfully and appropriately cross referenced with Planning Policy Wales (‘PPW').
Assessments and Standards for Open Space
3 FIT Cymru supports the need for local audits and assessments of all forms of open space. We support, and have done for some 20 years, the need for locally determined standards. FIT Cymru has never sought slavish adherence to the Six Acre Standards (‘6AS') but it is important to recognise that the 6AS has proved a very useful basis on which local policies and standards have been developed. In this context, we are pleased to see references to the 6AS in paragraphs 1.26 and 1.38 and the Annex.
4 FIT Cymru supports the need for standards which deal with quantity, quality and accessibility. This approach has been increasingly incorporated into recent revisions of our own 6AS, notably in 1992 and 2002. We are also pleased to note the typology of open space given in the Annex. The 6AS deals only with outdoor playing space, that is land for outdoor sport and children's play. Unfortunately, in the past, planning authorities have sometimes used the 6AS incorrectly as a standard for open space generally. The inclusion of the typology clearly identifies 10 different forms of open space all of which need to be taken into account when preparing open space assessments and determining development plan policies. This is most welcome and points planning authorities clearly in the right direction.
5 FIT is concerned about the content of paragraph 1.40. Planning for Sport, Recreation and Open Space has all too often been the poor relation of land use planning. To state that ‘Local Planning Authorities should not delay work on the preparation of LDPs where they have not prepared an Open Space Assessment' is to encourage bad practice. Alternative wording is suggested as follows: "Local Planning Authorities should ensure that an Open Space Assessment has been completed as an important part of the preparatory work for developing LDPs".
Protecting and Enhancing Existing Sport, Recreation and Open Space Facilities
6 Paragraph 2.7 could benefit from strengthened wording. It could be stated that "When not required for their original purpose, playing fields should be used to provide for any other form of open space in the wider community where any deficiency exists. If no deficiency exists, then alternative, built development can be considered."
7 Paragraph 2.8 refers to paragraph 11.1.11 of PPW where "the retention and enhancement of facilities may best be achieved through the redevelopment of a small part of a site". Experience has shown that the interpretation of the term ‘small' has been varied. It would be helpful if there were clearer guidelines on what constitutes a "small part".
8 FIT Cymru supports the provision of all weather pitches (paragraph 2.11) provided that at least one grass pitch exists on the site concerned, if it is an existing playing field or sports facility.
9 It is noted that while playing fields are protected, smaller areas of land for sport are not. The following measures are recommended:
Reduce the minimum size of the definition of a playing pitch to 0.2 hectares (currently 0.4 hectares)
Extend the need to consult the Sports Council for Wales for other sports facilities (e.g. athletics, bowls, tennis, multi-courts) as currently suggested by the Scottish Executive in its consultation on Scottish Planning Policy 11:Physical Activity and Open Space
Extend the need to consult the Sports Council for Wales so that any playing field used in the last 10 years (as opposed to 5) triggers referrals
Planning for New Open Space and Recreation Facilities
10 In regard to provision in new developments, FIT Cymru supports the provision of multiple use open spaces and facilities where appropriate, though some forms of provision such as children's play areas need to be dedicated facilities. We would also express caution about educational facilities acting as a community focus 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 desirable.
11 FIT considers the section on children and young people to be clear and helpful, dealing as it does with the need for a variety of provision in dedicated and non-dedicated settings, and consultation. FIT Cymru strongly recommends that the need for casual play space, based on multifunctional open spaces, in housing developments is included.
New Developments and Active Design
12 Finally FIT would also suggest 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, increasing awareness and emphasis on active travel (walking, cycling), co-location, formal sports and leisure provision and informal activity and recreation.
Further Contact
13 Please get in touch with:
Rhodri Edwards,
Development Officer, FIT Cymru
02920 230637
07940 822834
rhodri.edwards@npfa.org
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