To: Eveleen Riordan / LBH Principal Policy Officer
cc: LBH LDF team, Paul Ely / LBH Recreation & Leisure Policy
bcc: Haringey's Friends of Parks groups, Haringey's Residents Associations, Haringey Allotments Forum, Haringey Play Association, Haringey Councillors

24.1.2008

Includes attachments: [NOT INCLUDED]
- Open Spaces Strategy consultation response (July 2007), including GLA Guidance to Local Authorities re: Standards.. Standards
- Amended Open Space Deficiency Map

Includes Appendix 1:
- Haringey Allotments Forum response to the OSRS - draft SPD

Thank you for extending the deadline to enable us to properly consider and compile this detailed response.

1. We welcome the extremely important Open Space and Recreational Standards - Supplementary Planning Document [November 2007], and the establishment of formalised standards for creating and improving open spaces and recreational amenities in Haringey neighbourhoods. This is something that we argued and campaigned for during the consultation over the Haringey UDP in 2003-6, and which, as a result, the HUDP Inquiry Inspector stated in his report that he expected the Council to produce. The proposed document, if properly drafted, will profoundly affect development in Haringey and the funding for improvements to open spaces.

2. In particular we welcome the recognition that those engaged in development in the borough have an obligation to contribute to creating and improving open spaces and recreational amenities.

The Haringey UDP 2006 itself states: ‘Haringey’s open space falls below the National Playing Field Association’s 2.43ha per 1000 of the population, standing at only 1.7ha’. This is a substantial a shortfall showing a deficiency of 43% below minimum standards. The Haringey Open Space and Sports Assessment 2003 [aka the 'Open Space Survey' or 'The Atkins Report'] shows, in Vol 1, Table 4.2, that Haringey residents have far less open space per resident (590 residents per hectare) than the London average (363 per ha).

The deficiency is further exacerbated by the artificially low census calculations (which the Council has estimated as 5-10% below the true population figure).

And the population of Haringey is projected to rise 35,000 by 2016.

3. We have concerns that some of the key proposals in the current draft Supplementary Planning Document fail to conform to the recognised official minimum standards to which Haringey residents are entitled. Remedying this, and ensuring that these proposals are amended to conform to the official Guidelines, will make a real difference to all residents and communities throughout the borough, and ensure that the Council receives the funding from developers to which it is entitled.

This is explained in the following paras, with 17 specific amendments sought [listed in Sections E and F].

B. The obligation to identify and adopt the recognised deficiency criteria

4. This Joint Response focuses mainly on the fundamental issues of identifying the areas and extent of the deficiency of various types of open space and recreational amenities. Ensuring such deficiency is accurately mapped, based on recognised criteria, is crucial as the recognised deficiency is the 'trigger' for developers' obligations and therefore contributions.

5. Identifying the appropriate criteria is not difficult as these have been set out clearly in the Mayor's London Plan [Feb 2004], and the accompanying 'Guide to Preparing Open Space Strategies - best practice guidance of the London Plan’ [Greater London Authority, March 2004]. Such Guidance is not only very helpful, it is of course the dominant Planning Guidance to which all boroughs should conform.

6. The Council accepted the GLA Guidelines when they agreed the following in the LBH Open Space Strategy - Action Plan (in November 2005), Objective 1.2: ‘To adopt the GLA Guidelines for provision of the different types of open space as the standard to which Haringey will work towards.’ ‘Priority: High’ ‘Timescale: Immediate’.

7. It is now January 2008 and we expect, as agreed, the GLA Guidelines to now be adopted. For ease of reference they are set out in the attached document.

C. The background arguments, and relevant extracts from London Plan Guidance

8. The attached document consists of extracts from the Haringey Friends of Parks Forum / Haringey Federation of Residents Associations document originally submitted on 15th September 2005 for the LBH Draft Open Space Strategy Consultation (2005). It was re-submitted as part of the July 2007 consultation over the preparation for the current draft Open Space and Recreational Standards - Supplementary Planning Document. It is hereby re-submitted as part of the response to the Council’s currently proposed draft Open Space and Recreational Standards Supplementary Planning Document [November 2007].

9. The attached document, which incorporates the relevant extracts from the 'Guide to Preparing Open Space Strategies - best practice guidance of the London Plan’ [aka the 'GLA Guidelines'] should be read in full as part of this Joint Response. There is no need for us to re-draft that document as the arguments, context, references and Guidelines remain as valid for local Councils today as ever. This is even more true as the population of Haringey continues to rise.

10. At the Examination in Public at City Hall into the Further Alterations to the London Plan (Summer 2007) many participants - including the Haringey Federation of Residents Associations - argued that the London Plan policies on social infrastructure needed to be strengthened and properly enforced. No-one suggested at any stage, not even the property developers who made presentations, that any of the Guidelines should be watered down.

It should be noted that the Further Alterations to the London Plan include an addition to Policy 3D.7 in the Plan. The addition is: 'All developments will be expected to incorporate appropriate elements of open space that make a positive contribution to the wider network.' This addition underlines the fact that it is recognised that the direction of travel for policies on creating and improving social infrastructure are towards being strengthened and enforced.

D. Minimum standards must be adopted and enforced

11. The key points about using the officially recognised criteria for assessing deficiency is that:

i. They are minimums. We have no objections to anyone aiming for higher standards for Haringey residents, but obviously a minimum standard is one that should not be undercut. Minimum standards are used to identify the facts of the true levels of deficiency our communities face throughout Haringey.
ii. They are aspirational. They are standards to aim for, whilst recognising that already existing high population densities and over-development mean that we may not be able to achieve all the open space and amenities we are entitled to seek.
iii. They are 'trigger points' which will lever in a range of new facilities, additional resources and improvements. Residents and the Council alike stand to benefit from ensuring the minimum standards are fully adopted and enforced robustly.

12. We should therefore work together to ensure that Haringey residents and the Council are not sold short by any watering down of the recognised minimum standards as set out by the GLA Guidelines. As the Standards are set out clearly in these GLA Guidelines there can be no effective obstacles to their implementation (eg objections from developers). To refuse to implement them would only serve to benefit developers at the expense of our communities.

13. We know that our approach is the right one because we outlined all these points before to John O'Neill, Senior Planner at the Greater London Authority in June 2006. Responding to our concerns that at that time that Haringey Council was greatly underestimating the extent of open space deficiency throughout the borough, he replied (14.6.2006):

'Yes you appear to reflect the approach set out by the London Plan. Just to clarify that the deficiencies are normally calculated for each of the categories in the London Plan public open space hierarchy (Table 3D.1) and that while the larger parks perform the function of smaller parks this is not the case vice versa. For example, a District Park will also perform as a Local Park but not the other way around.

'As you rightly state the London Plan sets a benchmark for the provision of public open space across London and if the borough is deviating from that then it needs to set out a robust justification to explain why Haringey residents will have worse provision than can be expected in other parts of London.'

E. The current SPD draft proposals - amendments sought to Table 2.1

14. We note that the current draft Open Space and Recreational Standards SPD [November 2007], Table 2.1 - Open Space Standards in Haringey sets out the proposed Standards which should identify the criteria for assessing deficiency throughout the borough. These are the crucial, enforceable, Standards which will serve to trigger and guide planning contributions from all future development.

The key question is: Are the draft Standards used in the Table the officially recognised minimum Standards? If not, they would clearly require amendment, as would the accompanying text.

15. Unfortunately some of the crucial Standards have been watered down and require amendment. We therefore formally apply for all the Standards in the table to be brought up to the officially recognised Standards refered to above, below and in the attached document.

This includes the following examples from Table 2.1:

i. Public Park provision - Standard:

Amendment 1. '1.65 hectares per 1,000 population' to be amended to read: '2.43 hectares per 1,000 population'.

Reason: This would then be in conformity with the Haringey UDP statement, para 8.30: '...Haringey's open space falls below the National Playing Field Association's 2.43 hectares per 1000 of the population standing at only 1.7 hectares.' Indeed, the currently proposed '1.65 hectares per 1,000' would be below the current borough average!

Amendment 2. 'All residents within the Borough should have access to a public open space or park within 400m from home.' to be amended to read: 'All residents within the Borough should have access to a local park within 400m from home, and a small open space less than 280m from home.'

Reasons: This is an absolutely crucial distinction, not a pedantic one. The words and criteria being currently proposed mean that any neighbourhood with a tiny scrap of green space >0.25ha would not be identified on the deficiency map as 'deficient in open space' and hence developers in such areas will argue they have no obligations to provide or improve open space for the surrounding community. In contrast, the amendment we propose uses the officially recognised London Plan planning terms 'local park' [>2ha, with various facilities and amenities] and 'small open space' [<2ha, not necessarily containing any facilities].

This amendment would then make this standard clear rather than fudged, and more importantly in conformity with the deficiency criteria set out in the London Plan itself, in Table 3D.1.

The Amended Open Space Deficiency Map: We attach an accurate Amended Open Space Deficiency Map of the borough based on the criteria set out in the London Plan Table 3D.1. The Map is simply and entirely the 'Atkins' Open Space Study 2003 map 4.2 'Pedestrian Accessibility: Local Parks', incorporating the larger parks as set out in the 'Atkins' Open Space Study 2003 map 4.3 'Accessibility to District, Metropolitan and Regional Parks'. This shows that half of the borough is deficient in open space by official standards, rather than only the 20% identified by the currently proposed Map. The currently proposed Deficiency Map is based on the incredible claim that a neighbourhood is not deficient in Open Space if there is any scrap of green open space >0.25ha (even without any facilities) within 400m of people's homes, rather than an accessible Local Park with a range of facilities.

The Amended Map, as it is based on the London Plan, would take precedence in planning terms over any other map created by the Council. To avoid any confusion during development processes and appeals, and to avoid enabling developers to try to sell our communities short, it should be adopted immediately.

ii. Children's Play provision - Standard:

Amendment 3. '3sqm of play space per child' to be amended to read: '6sqm of play space per person'.

Reason: This conforms to the NPFA minimum standard [quoted in the GLA Guidance - para 2.81] for children's play, being 0.2-0.3ha outdoor equipped playgrounds and 0.4-0.5ha informal play space per 1000 population. ie 0.6-0.8ha children's playspace per 1000 residents.

Amendment 4. 'Doorstep Playable Space at least 100 sq.m in size within 100m of home' to be amended to read: 'Doorstep Playable Space at least 100 sq.m in size within 80m of home' .

Amendment 5. 'Local Playable Space at least 300 sq.m in size within 400m of home' to be amended to read: ''Local Playable Space at least 300 sq.m in size within 300m of home'

Amendment 6. 'Neighbourhood Playable Space at least 500 sq.m in size within 1000m of home' to be amended to read: ''Neighbourhood Playable Space at least 1000 sq.m in size within 1000m of home' .

Reasons for the above 3 amendments: According to the GLA Guidance [para 2.81. Table 5] there should be a Local Area for Play within 60-100 metres of all homes, and a Local Equipped Area for Play (with at least 5 types of play activity equipment) within 240-400 metres (depending on accessibility), and a Neighbourhood Equipped Area for Play (with at least 8 types of play activity equipment) within 1000 metres.

Amendment 7. Bearing in mind the above amendments, the 'Standards For Children's Play Provision' at page B-4 should be amended accordingly, including the specifications above about amount of types of play activity equipment.

iii. Playing Pitches - Standard:

Amendment 8. '0.57 ha per 1000' to be amended to read: '1.68-1.8 ha per 1000'

Reason: This is the figure recommended in the GLA Guidelines, at para 2.81.

Amendment 9. 'All residents should have access to playing pitches within 400m of home' to be amended to read: 'All residents should have access to playing pitches within 280m of home'.

Reasons: The Council's own Open Space Assessment [The Atkins Study, 2003] recommends that the ‘minimum standard of access to outdoor sports pitches within Haringey should be that “All households should be no more than 280m from an outdoor sports pitch in secured public use”‘

The 280m yardstick is also quoted in the OS&RS SPD Sustainability Appraisal, Tabe 3.3 under 'Outdoor Sports Facility Deficiency'. This Table also flags up that haringey residents have less than half the London average access - ie 1 pitch to 2,813 residents compared to the London ratio of 1 pitch to 1,335 (and only a third of the national ratio of 1.989).

iv. Natural and Semi-natural Greenspace - Standard:

Amendment 10. 'All residents should have access to an area of a Site of Importance for Nature Conservation of either borough or Metropolitan Importance within 500m from home' to be amended to: '.....within 280m from home'

Reason: The Council's Open Space Strategy para 3.28 recognises that the LPAC/GLA standard for areas of nature conservation value is a catchment area of 280 metres.

v. Allotments - Standard:

Amendment 11. 'All residents should have access to an area of allotment within 800m of home' to be amended to: All residents should have access to a substantial area of allotment (>0.8ha) within 800m of home'

Reasons: The Haringey UDP [para 8.39] states unequivocally that: 'Local authorities are duty bound to provide allotments for their residents if they consider there is a demand under Section 23 of the 1908 Allotments Act (as amended)'.

The Haringey UDP [para 8.40] recognises that 'there is an estimated requirement for up to 1552 additional plots or [an additional] 31ha of allotment land'... However, The Atkins Open Space Survey Vol 1, para 8.55 states:‘The way in which plots are promoted and publicised also influences demand. At present very little active promotion and publicity has taken place’. Even to achieve the artificially low number of total plots required, every ward should have an average of around 175 plots (about 15 plots for every 1000 residents). [For example, the three wards in S.Tottenham currently have a combined total of 63 plots and hence require an additional 462 plots to meet needs]. The former Haringey UDP (1998) states that there should be a substantial site, more than 0.80ha, within 800 metres of every household. [The 2006 HUDP contains no figure]. This former HUDP is a very useful standard and bench mark, which should be adopted.

Important Note: Please see the more detailed Response from the Haringey Allotments Forum [Appendix 1, below] which we support.

F. The current SPD draft proposals - other amendments sought

16. Should any or all of the above amendments be accepted there is obviously a need to amend other relevant and related paragraphs and tables.

17. In addition we propose the following regarding Table 2.8 - Thresholds for On-Site Provision

Amendment 12. For 'Public Park Small Local Park' amend the threshold from '100 dwellings' to '20 dwellings'

Amendment 13. For 'Children's Playable Space' amend the threshold from '30 dwellings' to '5 dwellings'

Amendment 14. For 'Playing Pitch provision' amend the threshold from '600 dwellings' to '100 dwellings'

Amendment 15. For 'Natural and semi-natural greenspace' amend the threshold from '60 dwellings' to '30 dwellings'

Amendment 16. For 'Allotments' amend the threshold from '200 dwellings' to '100 dwellings'

Reasons for Amendments 12-16 above: The best kind of provision of open space is public provision as close as possible to where people live. This will also ensure development benefits the immediate neighbourhood, avoids neighbourhood fragmentation, and aids community cohesion rather than provide gated or isolated developments.

18. Regarding para 2.38, second sentence there seems to be a typing error.

Amendment 17. '...a two bed dwelling...' to be amended to read: '...a one bed dwelling...' [in conformity with Table 2.5.]

G. Response to previous comments from public organisations, as set out in the SPD Sustainability Appraisal Report

19. There are a couple of references in the SPD Sustainability Appraisal Report [eg para 4.2] to the relevant National Playing Fields Association standards being 'not applicable in London due to the physical constraints on space and development'. This is not true at all. What the GLA Guidance says [at para 2.81] is that: 'the standard of 2.43ha of outdoor playing/recreational space per 1000 population is for many boroughs an unattainable target but can assist in strategic open space planning for children's play and active recreation.' [Our emphases]. Hence this refers to just one of NFPA standards, that it might be unattainable in many but not all boroughs (but of course still a marker of the level of deficiency), and that in any case it can still be used 'in strategic open space planning' - such as for this SPD.

20. The Sustainability Appraisal Report further states [in Appendix A, page 4, second row (response to Joint HFRA/HFoP comments)] in respect of the SPD's failure to adhere to the London Plan Table 3D.1 on open space deficiency re local parks: That the SPD 'reflects a more accurate representation of open space deficiency in Haringey, as the GLA hierarchy only sets out 'typical' characteristics and 'typical' sizes.'

This seems to say that we can't have an accurate measure of deficiency in Haringey because the deficiency is too great - so we'll make up some new criteria and at a stroke the deficiency is less! No doubt the same statistical sleight of hand could apply to a whole range of national indices measuring deficiencies in income/health/housing/educational standards etc.

This flimsy and incoherent argument undermines the needs of Haringey residents, is not credible, is not supported in the London Plan, and would drive a coach and horses through the London Plan's efforts to assess the true scale of open space deficiencies (and no doubt other social infrastructural deficiencies) in London boroughs.

Haringey residents and communities deserve better. We call on all Councillors and the Council to ensure that the proposed amendments are made.

Sincerely

Joan Curtis
Secretary, Haringey Friends of Parks Forum

Dave Morris
Secretary, Haringey Federation of Residents Associations