Dear Boris Johnson, Mayor of London
Mayor of London (2009) The London Plan: spatial development strategy for Greater London, Consultation draft replacement plan, October
Specific comments on Policy 3.6 – Children and young people’s play and informal recreation facilities (p71)
London Play contributed comments to the London Plan Review Initial Proposals in June 2009. Having consulted with our membership and with colleagues in other related sectors, we are pleased to submit hereby some views and suggestions about the Replacement London Plan which we believe will strengthen policy and practice across the capital, providing young Londoners the best possible play and informal leisure opportunities.
London Play was thrilled – and grateful to the Mayor – for being allowed to display photos in a major exhibition at City Hall during summer 2009, about our now award-winning Street Play project.
London Play aims for every child in London to have quality, accessible and inclusive play opportunities, near to their home. This objective is now matched by the Government’s new Play Strategy for England launched jointly in December 2008 by DCSF, DCMS and Play4Life from the DoH. http://www.dcsf.gov.uk/play
London Play aims to ensure that the ‘Guardians of the Public Realm’ are better able to differentiate between children’s play (which is pro-social) and anti-social behaviour. Work has already progressed under local Play Strategies; for instance in Hackney, Police Community Support Officers receive basic training in supporting pro-social play for children.
Play is essential to children’s growth and development. It is the medium through which they learn about the world and come to an understanding of their own nature and capabilities. However, because it is a child’s most natural impulse and therefore not necessarily requiring adult intervention or support, this most fundamental and vital part of growing up has been increasingly taken for granted.
Modern living, particularly in large cities, presents a significant range of obstacles to this essential childhood experience. There is a need for continuing serious investment of resources to provide our children with the environments, the opportunities, the access and the support to play.
Some children face greater obstacles than others and, in being excluded or denied this basic right, lose part of their childhood. As a consequence they lose out – emotionally, socially and educationally.
Play and recreation are a child’s right, as recognised by the United Nations Convention on the Rights of the Child. As the capital city, London owes a duty to develop realistic and achievable policies for children that take account of this right and provide the framework within which it can be ensured, for all children.
About London Play
- London Play is a well established charity that campaigns to promote play for every child in London
- London Play was established in 1998 (as the primary response to the Torkildsen report, 1996) via a consortium that included local borough Play Associations; the charity celebrated its tenth anniversary in 2008
- London Borough Grants Committee initially funded the organisation; now called London Councils, it still supports London Play to offer strategic support to play organisations and play providers in the voluntary sector and local authorities
- London Play is an independent voice for the play sector
- London Play brings together play associations and networks across London and promotes the consistency of play across the boroughs
- Current activities include the popular Street Play project (funded by the BIG Lottery) and Natural Play project (funded by corporate sponsor ICAP and Natural England)
- London Play’s website – www.londonplay.org.uk – has information about all matters play, and receives an ever increasing number of monthly ‘hits’
- London Play hosts a number of influential seminars throughout the year attracting altogether hundreds of professionals
- London Play has a number of influential patrons including Lord Smith of Finsbury, Jon Snow, Polly Toynbee and Simon Hughes MP
- London Play has 10 trustees with extensive experience in the play sector and a passion for children’s play, and a staff team of nine dedicated and talented individuals
- London Play is a membership organisation with currently around 300 members
Influencing London’s policies and strategies
London Play has a sound track record influencing the policies, strategies and practice that impact on play in the capital.
- London Play was commissioned to write the Guide to Preparing Play Strategies for the Mayor of London, published in 2005
- London Play contributed to the development of the Supplementary Planning Guidance ‘Providing for Children and Young People’s Play and Informal Recreation’, published in March 2008
- The Supplementary Planning Guidance incorporates recommended benchmark standards to inform the preparation of local Play Strategies
- It became a new requirement to provide 10 square metres of well designed play and recreation space for every child in new housing developments, appropriate and accessible facilities within 400 metres for 5-11 year olds, or within 800 metres for 12 plus age groups.
- In June 2009, London Play wrote to you, the Mayor, raising concerns about the lack of reference to play in the London Plan Review – Initial Proposals
- We are pleased that The London Plan – Spatial Development Strategy for Greater London – Consultation draft replacement plan (October 2009) contains Policy 3.6 – Children and Young People’s Play and Informal Recreation Facilities (p71).
Comments on Policy3.6 – Children and young people’s play and informal recreation facilities (p71)
London Play is heartened to see this policy commitment in the Replacement London Plan. We believe that the combination of Policy 3.6 on children and young people’s play and informal recreation and the existing Supplementary Planning Guidance which embodies recent thinking on play needs, together provide a good basis to plan for play and to challenge, where necessary, developments which fail to provide adequately for children’s play space. It would have been helpful to see the word ‘should’ replaced by ‘must’ or ‘will’ as these would strengthen the various relevant statements.
In addition, it is important that the very latest documents and guidance be incorporated and promoted; this could be done as a dynamic process as in the past two years or so there has been and continues to be a greater visibility of play in policy and practice.
To name just two such documents in particular: Play England’s (2009) Better Places to Play Through Planning, and the Department of Health (2007) Guidance on Joint Strategic Needs Assessment. The former provides an up to date overview of related policy and guidance for planners and local authorities to develop local standards. It argues that ‘as part of the assessment of local need there should be a review of national, regional and local plans and strategies with the potential to influence children and young people’s access to play. These will be contained in many different strategies and plans, and not just local planning documents’ (p10).
It is therefore important that the enhanced Policy 3.6 also be cross-referenced to other parts of the London Plan (Spatial Development Strategy) such as Section 7 – London’s Places and
Spaces’ – as well as be embedded in the wide range of other strategies, for example, the Mayor’s Transport Strategy, Health Inequalities Strategy, Child Poverty Strategy, Housing Strategy, Economic Strategy, Cultural, and Parks and Open Spaces Strategies. This needs to be replicated, of course, at local level to turn policies and strategies into action. For example, there are still many ‘gardens’ in public squares in areas of dense housing that could be brought into use for children’s play and informal recreation, while having to be safeguarded against being built over, with communities thus losing valuable open spaces. Similarly, many of London’s historic and amazing adventure playgrounds are under pressure and several face closure as developers want to use the land for other purposes, thus shrinking outdoor playable spaces even further.
Please also consult the Appendix for a wide range of additional resources and areas for connecting play with other strategies, developed by Alan Sutton, London Play’s Development Team Manager. These need to be referenced in the London Plan to help ensure a greater awareness of and therefore better planning for play.
London Play would be delighted to contribute more specific information during the consultation process, and is looking forward to working with the Mayor to make the capital a more child- and play-friendly city.
Dr Ute Navidi
working for a capital where all children can play
Additional sources and highlights of areas for connecting play with other strategies
By Alan Sutton | Development Team Manager
Health Benefits of Play – Physical and Mental
(having contributed to the separate Health Inequalities consultation)
Children benefit from free play, (free of charge, free to come and go, free to choose what to do), as it helps them to stay fit, have fun and make friends, developing sympathy, empathy and resilience for themselves at the same time as reducing the risk of obesity, anxiety and depression.
London Play has a focus on the rights of children to be at play where they live, and the importance of adapting and changing both the built environment (making playable space, planning) and the social environment (feeling safe in public space, differentiating between anti-social behaviour and play, which is pro-social) for the benefit of children, rather than adapting children to the currently un-child-friendly environment we have created. This is exemplified in one borough Children and Young Peoples plan (Islington) by the focus on the importance of reducing traffic volumes and speeds, when another borough C&YP plan stresses only the importance of teaching children “kerbcraft”. This reaching out by the new Children’s Services Departments from the narrow professional boundaries of health, education and social work, and into the wider issues of the place of children in the urban environment is crucial to the success of play strategies.
In the long-term this widening of the remit of Children and Young Peoples Services, to reflect children’s rights to participate in the social life of their communities and to expect a positive environment to do so, can only be beneficial to everyone in the improvement to social cohesion, reduction in the fear of crime and the accumulation of social capital which can flow from good community based play provision for children, parents and families. This stands in sharp contrast to those who deplore the modern reduction in children’s ability to act independently because of the dangers of traffic, strangers and bullies, and offer only safeguarding procedures, childcare enclosures and safe havens in a hostile environment as the solution.
London Children and Play
Children in London have a difficult time playing out, nearly all deprivation indices show worse outcomes for children in London than for the rest of the country, and the trends show little improvement over time, indeed the current recession meant that some such as parental income and overcrowding is likely to deteriorate.
The Playday 2006 survey found that 86% of children prefer outdoor activities, including playing out with their friends, building dens and getting muddy, to playing computer games, yet half of 7-14 year-olds in London surveyed said they do not play out as much as they like, and they have the worst access to natural play areas – 10 per cent higher than the UK average. London’s young population has higher childhood obesity rates (18%) than anywhere else in the country, child poverty is worse (41% for all London, 51% for Inner London, 29% all England)) and more children live in workless households (27% for all London, 38% in Inner London, 14% for all England). Overcrowded housing conditions are also worse in London, for couples with dependent children it is 5% nationally rising to 12% in London, for lone parent with dependent children overcrowding is 9% nationally, but 19% in London.
Play in Local Strategic Planning
Every London Borough now has a Children’s Play Strategy as a part of the Children & Young Peoples Plan, supported by Lottery and DCSF funding for play improvements.
- London Play works to implement the UN Convention on the Rights of the Child; in particular Article 31 guaranteeing children’s right to play, and to ensure that play is considered by Councils and Children’s Trusts as a strategic issue in: –
- Children and Young People’s plans (C&YPP)
- Sustainable Community Strategies
- Local Transport Plans
- Public Open Space Strategies
- Local Development Frameworks
- PCT Physical Activity Improvement and Obesity Reduction plans.
Details are given below of how these strategies and plans relate to children’s play through guidance and information on their production and implementation.
Specific National Strategies, Plans and Guidance that Support Better Play for Health Improvement
Dept of Children, Families and Schools – National Play Strategy launched by DCSF end of 2008
The Play Strategy sets out policy and actions to improve opportunities for children’s play and wellbeing, including improving road safety, providing safe routes to and from play areas, traffic calming in residential areas where children play, and better built environment and transport planning to create more child-friendly environments. Several related publications are designed to strengthen the impact of the Play Strategy: –
The Outdoor Play Campaign Toolkit is intended to help councils plan, deliver and launch communications activities for the parents of children and young people in relation to Play Pathfinder capital build, play refurbishment or pre-existing facilities.
Advice from the Association of Chief Police Officers (ACPO) was set out in a letter to Chief Constables and Commissioners. This communication underlines the important role community based officers have in actively encouraging children and young people to play in public areas, safely. It is designed to ensure that Crime and Community Safety Partnerships have an understanding of the importance of children’s play, which is pro-social behaviour, and make a clear distinction between it and anti-social behaviour.
A letter to Directors of Transport and Chief Planning Officers was issued from 5 Government Departments (DCSF, DCMS, DfT, CLG, DH) to support the Play Strategy: www.dcsf.gov.uk/play It emphasises the importance of space for play, safe routes to play areas and the use of playable space as well as specifically designated play-areas.
Safe from Bullying The Department for Children, Schools and Families has published guidance on how local partners can work together to tackle bullying of children and young people in the community.
Play England has developed a range of resources including Designs for Play offering advice on designing play space, and other publications on maintaining natural play areas, the importance of risk in play and other briefings and advice.
Play England Tools for evaluating play provision: The local play indicators
These local play indicators have been developed to support both top tier and second tier local authorities in assessing and managing their own performance in providing play opportunities to local children. The indicators focus on participation, access, quality and satisfaction of local spaces and facilities for play and informal recreation. http://www.playengland.org.uk/Page.asp?originx_1246im_50386004856125m96v_20091015345o
Play England – Better Places to Play through Planning December 2009
Play England has developed this guide to support planning and transport authorities to develop and implement planning policy that ensures children and young people have access to high quality playable spaces close to where they live and spend their time.
The publication, funded by the Department for Culture, Media and Sport (DCMS), gives detailed guidance on setting local standards for access, quantity and quality of playable space, signposting benchmark standards for different types of local authority. It also shows how provision for better play opportunities can be promoted in planning policies and
processes. Giving detail of how local development frameworks and planning control can be utilised in favour of child-friendly communities.
Department of Health
Joint Strategic Needs Assessment
The Local Government and Public Involvement in Health Act 2007 requires PCTs and local authorities to produce a Joint Strategic Needs Assessment (JSNA) of the health and wellbeing of their local community. JSNA is a process that will identify the current and future health and wellbeing needs of a local population, informing the priorities and targets set by Local Area Agreements and leading to agreed commissioning priorities to improve outcomes and reduce health inequalities. In practice, the Director of Public Health, Director of Adult Social Services and the Director of Children’s Services will jointly undertake JSNA, working closely with Directors of Commissioning and Finance to help set strategic priorities and make evidence-based investment.
This guidance, which complements the statutory guidance Creating Strong, Safe and Prosperous Communities, provides tools for local partners undertaking JSNA. It describes the stages of the process, including stakeholder involvement, engaging with communities and recommendations on timing and linking with other strategic plans. It also contains guidance on using JSNA to inform local commissioning, publishing and feedback. http://www.dh.gov.uk/en/Publicationsandstatistics/Publications/PublicationsPolicyAndGuidance/dh_081097
Change 4 Life
Since the original borough Play Strategies were written, DoH has taken over sole responsibility for improving physical activity levels across the whole population. DoH is now responsible for activity and exercise promotion for health and to tackle obesity. The Change 4 Life programme has a specific component on Play, called Play4Life for details see http://www.nhs.uk/change4life/Pages/Play.aspx this programme promotes physical outdoor play, asking families to get involved, and to allow children to take risks, to enjoy the benefits of play, which include making friends and improving self-confidence as well as tackling obesity.
Healthy Lives, Brighter Futures: The Strategy for Children and Young People’s Health (2009) is a joint Department of Health and Department of Children, Schools and Families strategy. It promotes walking, cycling and play as well as the benefits of green space for mental and physical health. It also encourages Local Partnerships to promote child-friendly environments through local spatial and transport frameworks:
Healthy Weight, Healthy Lives (2008) is a cross-Government strategy. The initial focus is to reduce the proportion of overweight and obese children. It sets out and supports recommendations from the National Institute for Health and Clinical Excellence guidance ‘Promoting and creating built or natural environments that encourage and support physical activity’ (2008) which includes recommendations on transport.
The Health Protection Agency has published A Children’s Environmental Health Strategy for the United Kingdom (2009) it offers a range of recommendations to improve the health and wellbeing of children in the United Kingdom by changing the environment they live in: www.hpa.org.uk/cehape/
National Institute of Clinical Excellence has published NICE public health guidance 8 – Promoting and creating built or natural environments that encourage and support physical activity in January 2008.
The recommendations are the Institute’s formal guidance on promoting and creating built or natural environments that encourage and support physical activity. All the recommended interventions are likely to be cost effective.
The guidance offers the first national, evidence-based recommendations on how to improve the physical environment to encourage physical activity. It demonstrates the importance of such improvements and the need to evaluate how they impact on the public’s health.
All the recommendations are relevant when developing joint NHS and local authority strategies (for example, joint community strategies, access plans and local area agreements).
Recommendation 1 Involve all local communities and experts at all stages of the development to ensure the potential for physical activity is maximised.
Ensure local facilities and services are easily accessible on foot and by bicycle. Ensure children can participate in physically active play.
Recommendation 2 Ensure pedestrians and cyclists are given the highest priority when developing or maintaining streets and roads. (This includes people whose mobility is impaired.) Use one or more of the following methods:
- re-allocate road space to support physically active modes of transport (as an example, this could be achieved by widening pavements and introducing cycle lanes)
- restrict motor vehicle access (e.g. by closing or narrowing roads to reduce capacity)
- introduce traffic-calming schemes to restrict vehicle speeds (using signage and changes to highway design)
- create safe routes to schools (e.g. by using traffic-calming measures near schools and by creating or improving walking and cycle routes to schools).
Recommendation 3 Plan and provide a comprehensive network of routes for walking, cycling. These routes should offer everyone convenient, safe and attractive access to
workplaces, homes, schools and other public facilities. (The latter includes shops, play and green areas and social destinations.)
Recommendation 7 Ensure school playgrounds are designed to encourage varied physically active play. Primary schools should create areas (for instance, by using different colours) to promote individual and group physical activities such as hopscotch and other games.
NICE Public Health Guidance 17 promotes physical activity, active play and sport for pre-school and school aged-children and young people in family, preschool, school, and community settings:
- Provide children and young people with places and facilities (both indoors and outdoors) where they feel safe taking part in physical activities. These could be provided by the public, voluntary, community and private sectors (for example, in schools, youth clubs, local business premises and private leisure facilities). Local authorities should coordinate the availability of facilities, where appropriate. They should also ensure all groups have access to these facilities, including those with disabilities.
- Make school facilities available to children and young people before, during and after the school day, at weekends and during school holidays.
- Actively promote public parks and facilities as well as more non-traditional spaces (for example, car parks outside working hours) as places where children and young people can be physically active.
- Town planners should make provision for children, young people and their families to be physically active in an urban setting. They should ensure open spaces and outdoor facilities encourage physical activity (including activities which are appealing to children and young people, for example, in-line skating). They should also ensure physical activity facilities are located close to walking and cycling routes.
- Assess all proposals for signs restricting physical activity in public spaces and facilities (such as those banning ball games) to judge the effect on physical activity levels.
CABE Space Open Space Strategies- Best Practice Guidance
This May 2009 publication fully acknowledges the importance of play within open space strategies and is recommended as a guide to Luton’s public space development.
CABE Space’s new publication (April 2009), ‘This Way to Better Residential Streets’ offers some interesting ideas on making residential streets more playable:
Department for Transport The new DfT Child Road Safety Strategy incorporates a specific action point on creation of safe routes to play areas as well as to schools (Action 16, page 62).
The new Manual for Streets updates 30 years of giving car drivers precedence, to suggest it is now time for people to see their residential streets as places to play, meet friends and hold a street party.
The DfT has put together a new page on their website to bring together all current information about road safety for children. This page links to guidance, resources and activities for individuals and bodies responsible for educating children about road safety.
Free play: Improving children’s Physical Health
This Play England briefing highlights the official recommendations on obesity that relate to free play, leisure opportunities and access to open space.
http://www.playengland.org.uk/Page.asp?originx_362tu_60167791104190x41k_20071112435n Since this briefing was written in 2007, a number of further national strategies and guidance have emphasised the importance of play for combating obesity, see the section above. Some commentators have focused only on sport for improving physical activity levels, yet research shows that many children do not like or enjoy sports, while most children enjoy playing. Children use as many calories in free play as in sport.
Free play: Improving children’s Mental Health
London Play has already done some work inputting research evidence into the beneficial effects of play in green space for the Dept of Health’s New Horizons Mental Health improvement strategy for details see this link, and click on the download at the bottom of the page. http://www.londonplay.org.uk/document.php?document_id=1429 or go to www.londonplay.org.uk and click on Play and Playgrounds/Natural Play/Better Mental Health. Free play allows children to think for themselves, to make decisions for themselves, and to feel the consequences of those decisions. Play enables children to learn what cannot be taught, to find how others think and feel, and to learn sympathy, empathy, sharing and tolerance. Play in outdoor public space also enables communities to work together and improve their neighbourhood engagement, research shows that parents whose children play out know many more other adults in their neighbourhood than those whose children are not allowed out, and have a more positive view of their neighbourhood.
In particular, it is likely that boys can reach their teens before being allowed by worried parents to go into wider society alone, without having learnt by taking small knocks and bruises, both physical and mental, how to avoid over-reacting to perceived slights and insults by using deadly force. Only last month a teenaged boy was killed in London because he insulted another on the Facebook website.