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PLAYLINK response to Fair Play

Introduction

PLAYLINK welcomes the opportunity to comment on Government’s Fair Play, a consultation on the play strategy.

PLAYLINK has for over forty years worked with statutory and voluntary sector play providers to increase the quantity, and enhance the quality, of play opportunities for children and young people.

PLAYLINK started life in 1964 as the registered charity, the London Adventure Playground Association. In 1990 it transformed itself into the national charity PLAYLINK. In 2004 it moved to the commercial sector. The values, understandings and principles animating PLAYLINK’s current practice are the same as those that prompted the original charity’s foundation.

PLAYLINK activities

PLAYLINK’s activities link policy development, addressing key issues such as the relationship between risk and play [1], children and young people’s right to be seen and heard in shared public space, with direct, practical work on the ground. Its designs for play service, for example, designs and delivers play opportunities in a variety of settings: parks, nurseries, housing, playgrounds and open spaces.

PLAYLINK is working with local authorities - including Pathfinders and Playbuilders - and also with the voluntary and commercial sectors across different forms of provision, staffed and unstaffed.

PLAYLINK’s response to Fair Play

There has been some debate over the years about whether there should be a national play strategy. PLAYLINK has no fixed view on this. However, should there be such a strategy, as is now proposed,

PLAYLINK believes that it should:

  • establish key values, understandings and principles
  • form a broad framework that will inform local decision making
  • strike the right balance between being prescriptive, and being advisory.

Whether or not the right balance has been struck between being prescriptive and offering advice will always be a matter of some contention. Fair Play seems to be in some tension with itself about how to strike this balance. On the one hand it speaks of publishing, for example, design guidance, and of supporting ‘innovative, informed’ procurement practice, and on the other, it announces a capital intensive programme that is massively and unhelpfully prescriptive. More will be said about this below.

Two of the tests PLAYLINK applies to the strategy are:

  1. does Fair Play espouse the values, understandings and aspirations that we believe must underpin any practical action on the ground?
  2. to the degree that Fair Play can be said to meet the first criterion, to what extent does its specific commitments support, undermine, contradict or dilute its own stated intentions?

PLAYLINK welcomes many of the commitments to be found in Fair Play. The breadth of the document is impressive, as is the recognition that play does not, indeed should not, be confined to designated play spaces. That ‘children need to be seen and heard in the shared public space’[2] and that this must include their ability to play within it, will, we hope, inform actual approaches to, for example, policing and the management and oversight of public space.

It is impossible not to support in principle Government’s decision to allocate much needed and significant funds - £235m – to children and young people’s play. However, we have major reservations about the way it is to be deployed. More about this will be said below.

Equally to be welcomed is the commitment by the Secretary of State for Children, Schools and Families and the Secretary of State for Culture, Media and Sports’, in their Foreword to Fair Play, to ‘…promote discussion about how we could all do better at this and build a society with more and better play opportunities for all children to play.’ We are puzzled, however, as to the practical application of this commitment. More will be said about this below.

The commitment to address procurement and planning issues is particularly welcome. We fear, however, that this good intent will not translate into changes in practice sufficiently quickly to have a positive affect on the Pathfinders and Playbuilder programmes. This is a major concern which will be addressed in more detail below.

So far as developing better procurement practice is concerned, it will be important to ensure that the right balance is struck between paying heed to the views of, for example, the currently dominant and organised play equipment sector, and the views and practice of those whose founding premise about how best to create quality playable spaces is somewhat different from that of the equipment industry. It is important not to reduce the different approaches to a sterile debate about the utility of play equipment. PLAYLINK’s position is straightforward: of course some play equipment has a contribution to make in creating quality play opportunities. It is simply that decisions about whether to use equipment, and if so which, should be made as part of a design process that addresses the play space as a whole, including its wider context. PLAYLINK is alarmed by the Department for Children, schools and families’ web site Build your play space. More will be said about this below.

The degree to which ‘young people’ – broadly 13 to 18 years old age group – are included in a national play strategy is, in PLAYLINK’s view, a significant test of its relevance.

So far as our second test is concerned - to what extent do specific commitments support, undermine, contradict or dilute Fair Play’s stated intentions? - our view is that a key element of the Fair Play programme is, in practice, flawed and ill-judged. This assessment of the Pathfinder and Playbuilder programmes is made reluctantly and with regret.

The Pathfinder and Playbuilder programmes are key elements of Fair Play’s ambition. These programmes alone make a significant – unprecedented – call on public funds. It is right, therefore, that this response to Fair Play pays particular attention to the two programmes. Their intent, scale, and immediacy will have – is having – a major impact on the play sector. The programmes will create ‘facts on the ground’ for children and young people’s play for years to come.

Government’s commitment to promote discussion

PLAYLINK is puzzled as to how a Government ‘consultation’ document that aims to ‘promote discussion’ can at the same time insist upon two large spending programmes replete with detailed criteria, key indicators and spending timetables, all of which are required to be implemented prior to the results of the consultative exercise being known. PLAYLINK’s work with play providers in general, and Pathfinders and Playbuilders in particular, suggest that the two programmes, as currently formulated, represent a misreading of the ‘state of play’ on the ground. Here PLAYLINK’s analysis of market failure in the provision of play opportunities has particular salience: the rapidity with which money needs to be spent means that expenditure will be committed on too many occasions under conditions of market failure. There will be exceptions of course, where authorities have begun to address this, but even here, for the reasons we set out below, good intent is being undermined.

Market failure

PLAYLINK has identified ‘market failure’[3] in the provision of play opportunities. This market failure is substantially funded by public funds. By market failure we refer both to:

  • procurement processes, [4] often including misshapen and ill-advised consultation exercises that have as their issue the numerous woeful, identikit, equipment- dominated[5] play areas that litter the country
  • the content of procurement or tender requirements – overwhelmingly limited to the purchase of play equipment, more recently with occasional nods made towards something described as ‘natural play’.

Market failure arises because the demand side – play providers, significantly local authorities and Residential Social Landlords – stimulate and effectively fund the supply (procurement) of less than optimal play opportunities.

Whilst acknowledging the continued prevalence of this market failure, PLAYLINK is encouraged by the positive changes taking place in a number of authorities. This is reflected in, for example, tender documents that articulate an understanding of play in its widest aspects – not simply being about ‘letting off steam’ or spaces where equipment is parked – coupled with an appreciation that a space for play is a designed space, one that is part of, and can contribute to the attractiveness of, the wider environment. This process of change, however, has hardly begun, and is someway from being either widespread or secure. In the particular case of play provision, market failure can most effectively be countered by changing the nature of demand. As some authorities are already demonstrating, public authorities have in their hands the capacity to change radically for the better the nature of play opportunities. PLAYLINK is working with a number of these authorities.

Centrally determined and prescriptive

Pathfinder and Play builder programmes are centrally generated and unhelpfully prescriptive. Play provision is pre-eminently local provision. The ordering of priorities in support of play opportunities should be made at local level, as should decisions about the allocation of resources. Local authorities, with local community and voluntary sector agencies, are best placed to make judgments about what is required within individual local areas. It cannot be right that with £235 million to spend in England alone, local projects and initiatives that rely on revenue funds will not benefit from the infusion of taxpayers money. The balance between revenue and capital spending should be subject to local decision-making.

Unrealistic timetable and targets

Local authorities are required to spend significant amounts of money on capital schemes within totally unrealistic time scales. This will lead, in our view, to bad schemes being created. In practice the target will become ‘spend (or lose it) by the 31 March 2009 (in the first instance)’[6] rather than a target of creating best possible play opportunities, a process that takes time, planning and a responsiveness to the individual character and potential of each space for play. This work should not be artificially rushed, nor subject to ‘bulk buys’ – wrapping everything up with one supplier - because of the need for speedy procurement and therefore administrative convenience.

Procurement

PLAYLINK’s procurement and maintenance survey found that procurement processes for play systematically limited the range of choice open to play providers. Fair Play therefore rightly includes a commitment to address procurement processes, identified as one of the barriers to creating best possible play opportunities. Yet the first tranche of Pathfinder and Playbuilder programmes need to be implemented now, before progress can be made on changing procurement processes. Current standard play procurement processes systemically limit the scope for creating quality play opportunities. In this regard Fair Play, on the one hand, recognises the problem; and on the other, in effect proposes to address the question after major procurement decisions have been made. In this, Fair Play appears to contradict its own avowed purpose.

Approach to engagement mistaken

Fair Play’s understanding of ‘involvement’ and ‘consultation’, at least so far as the design of play spaces is concerned, requires more detailed consideration. Some of the most woeful play spaces have been created as the result of what is commonly called ‘consultation’. Fair Play needs to encourage play providers to take a more questioning and exploratory approach to the complex and sensitive areas of consultation, involvement and engagement generally.

In the field of nutrition, for example, it would seem odd simply to consult children and young people about their favourite food, and then give it to them. ‘Chips with everything’ is not Government policy. Government policy in the area of nutrition faces in precisely the opposite direction: it recognises that some diets are better than others and aims to fulfil a role that is, in part, educative. This is not the same as imposing decisions on people, it is about articulating an informed point of view.

The creation of play spaces requires the same degree of clarity. It is necessary to have a point of view. This is not the same as imposing it. This suggests that engagement with communities, children and young people should be a process of learning, exploration, and the articulation and examination of key ideas and principles.

PLAYLINK’s own work in this area – linked to the practical business of designing and implementing spaces for play schemes - suggests that people enjoy and value such an approach. The focus and output from any engagement should be the development of a design brief, couched in layman’s terms. It is then for the designer, or person with design competence, to respond to the brief in relation to the specific qualities of an individual site or area. It is this approach that is more likely to yield spaces for play that evoke a ‘sense of place’, that contribute to the potential beauty – yes, beauty – of the local environment.

Engagement should not focus on generating wish lists of equipment or indeed landscape ‘wants’; nor should play equipment catalogues be the primary vehicle for determining what constitutes a good space for play. What is required is development of a design brief.

Build your play space

The Department for Children, Schools and Families’ web site Build your play space is a graphic illustration of a mistaken and counterproductive approach to engaging with children and young people so far as the creation of quality play opportunities is concerned. To the degree that it replicates a not untypical approach to involving children and young people, it offers play providers an example of what not to do. It is, unfortunately, an approach that too many play providers and play equipment manufacturers (with noble and respected exceptions) undertake; it being web-based and perhaps thought innovative for that reason, changes nothing in principle. It is an example of bad practice.

Age ranges

PLAYLINK disagrees in principle with the age-bound limitation of this initiative. It is unhelpful and misunderstands the nature and fluidity of children and young people’s social groups, which are not rigidly age-defined. It suggests by implication that, for example, seven year and fourteen year olds are likely to want be doing something radically different from an eight or thirteen year old. It also fails to see the positive benefit of older and younger children mixing within the same social space. This does not mean that the needs and wants of very young children need be overlooked or marginalised.

It is difficult to see how a commitment, foreshadowed in chapter two of Fair Play, to children and young people up to the age of nineteen, is to be met by this initiative

Recommendation

PLAYLINK is not so naive as to suppose that its reservations are sufficient to turn around a programme that is now so firmly embedded. However, there remains scope for Government to create, within the broad terms of the Pathfinder and Playbuilder programmes, the conditions more likely to support realisation of the strategic aim of creating more and better play opportunities for children and young people. PLAYLINK urges Government to release:

  • Pathfinders and Playbuilders from the obligation to spend capital and revenue allocations by March 2009 (or the end of April 2009 under certain circumstances for capital only)
  • grant recipients from the potentially wasteful requirement to completely or substantially replace old equipment. PLAYLINK’s experience, and that of Stirling Council, suggests that old but not worn out equipment can be re-used creatively within a designed landscape.

So far as the recommendation to extend the period within which expenditure can be planned and implemented is concerned, it is based on the rationale to be found in Fair Play. That document confirms that, ‘In April 2008, 63 local authorities will begin using their funding to improve local play offers…’. In addition, it announced that, ‘ In order to create more high quality places to play, we propose to… provide clear guidance on developing interesting and fun places to play’.

Our understanding is that Pathfinders were not informed of their allocations until June 2008, and that funds have still to be released. In addition, the proposed ‘clear guidance’ has yet to be issued. Nevertheless, authorities are required to spend allocations, which range from £571,926 - £621,944 for capital, and £134,236 - £144,831 for revenue, by March 2009.

The logic of issuing guidance is, presumably, that it is required as an aid to best possible decision making. And Fair Play’s pronouncement that authorities will begin using their funds in April 2008 suggests that, at a minimum, authorities would have a full twelve months to implement schemes. This points to the need for an extension beyond March 2009 for expenditures to be made. Currently, with neither funds nor guidance available, authorities have something less than nine months to make key decisions, and to implement them. At a minimum, the logic of Fair Play is that there should be a full twelve months available to spend from the date funds are released and guidance issued. This suggests that, at the very least, the target date for spending the first year’s allocation should be no earlier than July 2009. Better still, the implementation process should be extended to March 2010. Getting the Pathfinder and Playbuilder programme implementation timetable right is no small matter. The capital to be deployed will in practice have to serve a number of generations. We wish to avoid the possibility that the programmes’ legacy will be monuments of regret for what might have been.

We turn now to other aspects of Fair Play.

Chapter one, What children and families have told us and what the evidence says, by implication at least, notices that people’s response to key issues - for example, safety, concerns about crime, older children, what adults think, what children want - do not resolve into an easy and shared consensus, but are sources of potential conflict and dissention. The implications are, however, not drawn out. This is unhelpful, for it sets a tone that suggests that merely by asking people what they want will wish away all difficulties.

Play in schools, children’s centres, nurseries and related provision

Rather than duplicate in detail comment that has been made elsewhere, PLAYLINK confirms its endorsement of the recommendations made by the Play in schools and integrated children’s settings group, of which it is a member.

It is, however, worth highlighting a number of issues that need to be addressed if the non-formal school day is to become play enabling. They include:

  • the need for Ofsted to understand specifically free play, and its relationship to risk. Inspectors often find themselves bewildered and anxious in observing manifestations of children’s freely-chosen play behaviour. An ill-informed negative Ofsted report on a school’s breaktime can undermine schools’ willingness to embrace and support free play.
  • our experience has been that schools, in particular primary schools and nurseries, are nervous about risk-taking in play. Training and support is required.
  • there is anecdotal evidence that suggests that schools built under PFI arrangements are less likely to release the school ‘asset’ for use by the community; or charges are made that are in practice prohibitive. This needs to be addressed.

More widely and radically, there needs to be a major cultural shift in the relationship of schools to their communities. The removal of fences bounding ‘school’ land would make a massive contribution to changing the perception of the school within the community, and make available acres of land for community use, not least play.

Playing safely

In respect of road safety, whilst accepting that it is useful to offer children ‘pedestrian training’, PLAYLINK takes the view that it is car and lorry speeds that need to be controlled along with measures that give primacy to the pedestrian, particularly in residential areas.

We welcome the proposals to:

  • provide parents with information about the benefits of, and opportunities for, outdoor play
  • tackle ‘current perceptions and barriers which exist about freedom and play for children’ and the communication campaign that will ‘endorse freedom and play for children’
  • ‘counteract negative perceptions’ of young people.

It is however not clear how these aspirations mesh easily with other aspects of Government policy and rhetoric, for example, the constant references to ill-defined ‘anti-social’ behaviour, or indeed the high rates of custodial sentences meted out to children by the criminal justice system.

The aim of creating quality play opportunities is undermined when play providers adopt an essentially defensive posture in relation to risk in play, in effect making their primary policy aim the avoidance of negligence claims, or parental complaint. This approach has systematically led authorities to ‘dumb down’ play provision. It has also fostered a mistaken view about the role of standards, and placed an artificial and unnecessary limitation on the creation of play opportunities that are not ‘standard’. This has led not only to the degrading of play opportunities but also to the creation of identikit play areas that contribute little or nothing to a local and unique ‘sense of place’.

It is an urgent matter that misunderstandings about risk’s relationship to play, and misunderstandings about the role and status of play equipment standards – they are not mandatory – are corrected.

The risk-benefit assessment approach to making judgments about play provision, to be a major feature of the forthcoming Managing Risk in Play Provision Guide to be published by Play England, needs to be widely promoted.

It is important that Health and Safety officers become fully conversant with the values and understandings underpinning the risk-benefit approach, as well as its practical implications.

Judges and the judicial system, particularly perhaps in respect of the lower courts, need to understand play and its relationship to risk taking.

All play providers must have a play policy. For local authorities in particular, this will create a formal framework that will assist them in determining what is ‘reasonable in the circumstances’ when making judgments about play provision. PLAYLINK’s play policy, adopted by many local authorities, is the subject of positive, authoritative legal opinion[7].

The Health and Safety at Work Act needs to be reviewed as to whether its terms are helpfully applicable to the general public realm, for example, parks, open spaces, play spaces. The role of the HSE in relation to the public’s use of the public realm needs to form part of such a review.

Child friendly communities

We welcome the general commitment to ‘make public space more child-friendly’. PLAYLINK’s play policy stance is that, ‘children and young people being seen and heard in public spaces is one of the hallmarks of a vital society.’

In terms of specific commitments in Fair Play, we welcome:

  • measures to be taken to ensure that the planning system, its policies and procedures pay proper attention to children and young people’s right to use and enjoy the public realm
  • proposals to address the need for quality play environments in residential developments.

We have particular concerns that house building targets are placing pressure on scarce open space, in some areas in particular. There is some evidence that roof gardens are considered by some authorities as contributing to meeting standards for amenity and play space. PLAYLINK is clear that specific guidance needs to be issued to ensure that roof gardens are considered as additional to amenity and play space standards[8].

Local community ownership of space suitable for play

As will be clear from PLAYLINK opening remarks to this response to Fair Play, we believe in principle that decisions about play provision must be, to a large extent, local decisions. We have also cautioned in this response against simplistic, mechanistic approaches to involvement, consultation and engagement. In this regard, how in practice the new duty to involve, referred to in Paragraph 5.28, is interpreted will determine to a significant extent whether play ‘places of woe or places of possibility’[9] will be created now and in the future.

Sustaining and embedding play

We welcome the recognition that, ‘play needs greater prioritisation locally, the skills and capacity of the play workforce need to be increased, and play provision included in local authority policies and performance management.’

We are, however, sceptical about the utility of developing a performance indicator that is in effect one dimensional: seeking only children’s views about their assessment of local play spaces. Children and young people’s views are not to be marginalised, of course. But there needs to be a more nuanced, sophisticated approach to the assessment of play opportunities than that to be gleaned from the views of children and young people alone. We refer back to the point we made earlier about adults’ and Government’s role in making judgments about what constitutes a good diet. Here children and young people’s views and wishes are part of a wider picture. Any proposed indicator needs to take a wider view than currently is proposed.

In summary

To summarise PLAYLINK’s response to Fair Play: we welcome many of its commitments, not least the £235m allocated to play. The breadth of the document is also impressive. However, notwithstanding the frenetic activity some of Fair Play’s stipulations have generated, in fact in part because of this, Government has itself limited the scope for play providers – who are delighted by Government’s interest in play - to translate good intent into best possible action on the ground. The reasons for this have been detailed above.

Endword

The views expressed in this response to Fair Play are PLAYLINK’s own. No claim is made that the views represented here have been formally supported by any other body. However, our response to Fair Play is based on what we believe is a sensitive reading of the state of play in the public sector. That reading emerges from the nature of PLAYLINK’s established and continuing relationship with play providers at all levels.

About PLAYLINK

PLAYLINK works directly with play providers at all levels. Its Landscape Architect Associates design and deliver playgrounds and playable spaces in nurseries, parks, open spaces, housing schemes and playgrounds. Our commitment, however, extends beyond the schemes PLAYLINK is commissioned to undertake around the country. We are also keen to disseminate knowledge and experience with the strategic aim of fundamentally changing the way play is understood and provided for in the UK as a whole. In this regard, PLAYLINK’s Play Study Tours, both those undertaken in local areas and the series of study tours that focus on Stirling’s play services’ experience, have been enthusiastically received for the way in which they link theory and values to practice on the ground.

In addition, PLAYLINK is known for its:

Bernard Spiegal
PLAYLINK
13 July 2008

  1. PLAYLINK’s Principal, along with Professor David Ball and Tim Gill, were commissioned by Play England, in collaboration with the Play Safety Forum, to write the Managing Risk in Play Provision (working title) guide. It should be published shortly.
  2. An understanding to be found in PLAYLINK’s play poliices.
  3. See ‘Places for Play: ailments and remedies’ at http://www.freeplaynetwork.org.uk/playlink/exhibition/editorial/index.html.
  4. See PLAYLINK’s Procurement and Maintenance Survey of local authority play providers at: http://www.playlink.org/articles/?p=20
  5. PLAYLINK has no in principle objection to play equipment. Indeed, it specifies equipment in its own schemes as appropriate. It is, however, opposed to the default position of so many play providers; that is, that play opportunities are created exclusively, or almost exclusively, through the provision of equipment.
  6. There is, currently, the potential for one months grace on capital schemes. This does not weaken the point being made here.
  7. See ‘Negligence, play and risk’ at http://www.playlink.org/articles/?p=8
  8. PLAYLINK welcomes any opportunity to explain the reasons why roof gardens are not generally suitable places for play.
  9. Places of Woe: Places of Possibility is the joint FreePlayNetwork/PLAYLINK online photo exhibition of play spaces at: http://www.freeplaynetwork.org.uk/playlink/exhibition/woepossibility/
  10. See ‘Negligence, play and risk’ at http://www.playlink.org/articles/?p=8
  11. PLAYLINK and the Association of Teachers and Lecturers were the founding members of the original Play in Educational Establishments Group that has now developed into the Play in schools and integrated children’s settings group, of which PLAYLINK is a member.
  12. See article ‘Lost Conversations: some thoughts on consultation’ at http://www.playlink.org/articles/?p=17
  13. See ‘Dialogue, not consultation – show, explore, learn and engage’ at http://www.playlink.org/services/designs_for_play/dialogue.html

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This entry was posted by admin on Monday, July 14th, 2008 at 12:21 pm and is filed under Open Letters, Policy and Strategy.

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