The Government’s consultation on proposed changes to the National Planning Policy Framework (NPPF) closed on Tuesday 10th March. This is the most significant rewrite of the NPPF since it was first introduced 14 years ago.
First published in March 2012, the NPPF sets out the Government’s planning policies for England and how they should be applied. Planning policy shapes much of how we live and the NPPF guides decisions to determine what gets built where.
Securing the long-term future of our parks, playgrounds, playing fields and green spaces remains at the heart of our cause. Below we have summarised some of the key points we’ve made in response to the Government’s consultation, both positive and negative.
We are pleased to see that the Fields in Trust Standards for open space, outdoor sports and play space are explicitly referenced in the draft NPPF text, pointing developers and planners to a familiar and instructive guide for consistently creating the right amount of quality, accessible green spaces for communities.
We also welcome the proposals to achieve well-designed, healthy, inclusive and sustainable places and strongly agree that green infrastructure should be classified as essential infrastructure and integrated as a core component of the decision-making process.
Having worked closely with sector colleagues, we welcome the recognition in the NPPF of the needs of children and young people in the planning system by including “play spaces” and “informal play” within the open space policy having previously been silent.
The revised NPPF has a strong “presumption in favour of sustainable development”, but we are pleased to see that the policy for ‘Sports, Open Space and Recreation Facilities’ carries material weight in the NPPF and can therefore influence decision-making.
While we genuinely welcome some of the proposed changes, we have also raised concerns where we believe the NPPF could be much stronger, particularly when it comes to protecting and creating accessible green spaces that are so essential to community health.
Crucially, we continue to seek explicit reference to the long-term legal protection of recreational open space within national policy. We are calling for a requirement for local planning authorities to treat this as a key consideration in both their plan-making and decision-taking, ensuring protection is the starting point for every local strategy. Fields in Trust’s independent and unique Deed of Dedication provides long-term legal protections to parks and green spaces benefitting today’s communities as well as future generations.
Many areas of the country already have a deficit of public recreational land according to findings from our Green Space Index. We believe there should be stronger requirement to assess existing provision, and therefore future needs of the local area, to avoid decisions being taken in isolation and potentially adding to the deficit.
A shift in the draft NPPF text is that any replacement green space provision needs to satisfy either a quantitative or a qualitative element. However, this signifies a risk in approach that may end up reducing the overall quantity and quality of open spaces, sport facilities, recreation facilities, and playgrounds within new developments.
Open space has to work hard and is often hugely contested but no opportunity to create the very best, within the funds available, should be missed. We should be aiming high every time, looking to restore or create spaces that have a great offer and support active lifestyles, that bring nature in at every turn, that work well and are the optimum size to meet the needs of local people. To ensure the best outcome, quantity, quality and accessibility need to be considered together and applied according to local circumstance.
We would recommend on-site provision combined with long-term protection of recreational open space is prioritised above financial contributions towards off-site provision by way of mitigation for any loss. Offering qualitative improvements off site often does not achieve the best outcome for the communities affected.
To support the Government’s intention to increase the speed of plan-making and improve consistency across the board, we recommend that the Fields in Trust Standards for open space, outdoor sports and play space are mandated in national policy and adopted in local policy – they ought therefore to become the starting point for all local plans by default – which chimes with the fact they are widely recognised and used daily by most practitioners.
We already see a high level of inconsistencies when it comes to the creation of green space as part of a development being under-delivered in this regard and the Fields in Trust Standards specifically set out to show how this bar should be raised.
We're also calling for the Fields in Trust Standards to be used when assessing replacement provision, so there’s a clear, independent way to measure whether communities are genuinely better off.
We strongly believe there is also a need to consider the draft NPPF in combination with proposed reforms to statutory consultee roles. If Sport England’s statutory role is removed, there will be no guaranteed protection for playing fields. Without this specialist advice and guidance in the system, local planning authorities will find it very challenging to navigate and decisions made will risk severely harming grassroots sport facilities and reducing community access both now and in the future.
We argue that layers of scrutiny should exist for all types of public recreational spaces and play spaces, regardless of designation or size – these spaces are solely reliant on policy for their long-term future which the evidence tells us is woefully insufficient. Current thresholds often exclude smaller but vital community spaces. But these are often the places where people learn to kick a ball, ride a bike or run – even modest green spaces deliver measurable health and wellbeing benefits.
We firmly believe that the delivery and long-term protection of open space such as publicly accessible parks, playgrounds and playing fields should remain at the heart of promoting sustainable development.
Our message is simple: affordable homes and green spaces are not competing priorities - planning policy should secure both outcomes for healthy communities to thrive, not force a choice between them.