Chapter 16
158) Do you agree with the approach to planning for healthy communities in policy HC1, including the expectation that the development plan set local standards for different types of recreational land, drawing upon relevant national standards? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI notes the intention of the policy that the development plans should set standards for the provision of outdoor recreational land, including play areas, sports facilities, informal recreation spaces and allotments, with reference to relevant national standards. Such national standards may benefit from more detailed recognition of matters such as participation trends, capacity, travel patterns and demand.
The institute is concerned that applying relevant national standards, locally, will be difficult without a full understanding derived from a comprehensive assessment of need. Without an assessment of need, it will be very difficult for decision-makers to understand whether such standards are being met in the first place.
We note the similar but slightly different approach to drafting HC1(a) as TR1(1)(a), which for example, cites the need for engagement to be undertaken early and consider other relevant strategies. The RTPI would welcome strengthening HC1(a) in this manner alongside the inclusion of the need to engage statutory consultees. HC1(1)(a) may benefit from a clearer link to policy provisions in Chapter 8, including using similar language seeking to enhance viability and vitality of town centres. A link to footnote 59 may better support the application of HC1 and HC2. The RTPI is unclear how this policy in its current form would be usefully engaged through the preparation of SDSs.
159) Do you agree that Local Green Space should be ‘close’ to the community it serves? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI welcomes the weight attributed to Local Green Space in the proposed Framework. As set out in response to Q135, the RTPI thinks that GB5 should be amalgamated into policy HC2.
We understand the emphasis and intention of the policy in its aim to ensure Local Green Space is close to the community it serves but note that what is considered close may be different in a rural setting and flexibility may need to be applied in these regards.
160) Do you agree that the proposed policies at HC3 and HC4 will support the provision of community facilities and public service infrastructure serving new development? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI welcomes the substantial weight attributed to proposals for new community facilities and public service infrastructure in HC4 and recognises the specific role in supporting the vitality of town centres.
We note footnote 59 references the green infrastructure standards for England and standards for open space outdoor sport and play produced by the Fields in Trust alongside Sport England guidance. Whilst we welcome the intent of such standards in guidance, there may be practical challenges when assessing development proposals in terms of consistency, as the separate respective guidance notes offer different approaches.
161) Do you have any views on whether further clarity is required to improve the application of this policy, including the term ‘fast food outlets’, and the types of uses to which it applies?
The RTPI supports the intentions of this policy, in terms of reducing health inequalities and childhood obesity rates. We do note potential complications around applying this policy, particularly if a school is a reasonable walking distance from a high street or local centre, noting that fast food outlets are an integral part of active and vibrant town centres.
162) Do you agree with the proposed approach to retaining key community facilities and public service infrastructure in policy HC6? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly disagree.
a) Please provide your reasons, particularly if you disagree.
The RTPI strongly supports the intention of this policy in terms of retaining key community facilities and public service infrastructure, however we have concerns about the applicability in practice. For example, decision-making on local health facilities will likely be beyond the remit of planning and defining the ‘last of its type’ facilities in urban locations may prove difficult. Therefore, the RTPI would recommend a reworking of this policy, including the removal of the last sentence in HC6(2). Such a reworked policy could take on a more positive framing, with reference to community asset-based approaches.
163) Do you agree with the approach taken to recreational facilities in policy HC7, including the addition of ‘and/or’ with reference to quantity and quality of replacement provision? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly disagree.
a) Please provide your reasons, particularly if you disagree.
Whilst the RTPI understands the need to provide some flexibility around the quantity and quality of recreational facilities for replacement provision, we hold some reservation that such an approach may end up reducing the size of open spaces, sport, recreation facilities, and playgrounds.
164) Do you agree with the clarification that Local Green Space should not fall into areas regarded as grey belt or where Green Belt policy on previously developed land apply? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly disagree.
a) Please provide your reasons, particularly if you disagree.
The RTPI notes some significant potential practical challenges if, as currently drafted, Local Green Space is to be determined in a manner that is consistent with the relevant national decision-making policies for land in the Green Belt. This is due to the differing nature of such policies considering, for example, the Green Belt’s role of checking the unrestricted sprawl of large built-up areas. Therefore, we recommend that the policy be deleted.
