Policy and Consultations

Lottery funding for children's play

Consultation Response Form

Yes

Comments

PLAYLINK broadly agrees with the descriptions set out in sections 2.4 to 2.8 of the Consultation Paper provided that they are interpreted as enshrining the childs right to play. However, the following should also be included:

1. Children have a natural impulse to play which is both functional for growth and development and leads to satisfaction and pleasure, contributing a vital element to quality of life throughout childhood

2. Risk taking is inherent to play, enhancing both benefits to children and their enjoyment

3. It follows from the emphasis on the child's control that the role of the playworker should be generally characterised as 'low intervention/high response'

4. Spaces for play (2.8) should include the creation of play opportunities in shared public spaces such as parks, streets, squares, housing estates.

5. A play environmnent can be anywhere where the needs and wishes of children are understood and their use of the space for play is facilitated

6. In principle, providing for play should be a universal 'service' though in practice there are areas where children are grossly deprived of opportunities for play often, but not invariably, associated with other indicators of disadvantage. These should be a priority for support.

no priorities

Comments:

PLAYLINK takes the view that this is the wrong approach to prioritising projects for funding.

The principle should be to base priorities on the needs and wishes of children rather than on particular types of provision and methods of service delivery.

This alternative approach allows for different local responses to different local needs (the criterion for providing good play oportunities set out in section 4.2 of the Consultation Paper).

It also provides a framework for the development of a flexible range of provision and services which would not necessarily fall within descriptions of the current range as in the list above.

It is particularly important to foster this approach given the number of existing, and new initiatives eg local Prevention Strategies and the Green Paper on Children at Risk, which promote a more holistic response to the child by children's services. A play ethos, together with play provision and services have much to contribute to these intiatives. Confining the distribution of NOF funds to existing categories of provision is likely to stifle holistic, creative and innovative responses to children's needs and wishes.

The aim should be to look at the best way of providing a full range of play experience for each child in a given neighbourhood. New provision should build on the existing mix of local provision and play opportunities to meet criteria set out in 'Best Play:what play provision should do for children' particularly Appendices A and B. Enhancement of existing provision, amendment or add ons to other services and opening up access to public space to allow for play should all qualify.

Agree

Comments:

In principle, PLAYLINK agrees with the proposal for local distribution though we believe that local discretion should be within a framework of overarching criteria attached to the NOF fund. These should be founded on the widely accepted principles, values and assumptions about children and play that are set out in 'Best Play..' and inform quality assessment and assurance schemes and playwork training.

Experience of distributing the NOF Better Play programme funds has demonstrated the limitations in relying on crude deprivation indices as indicators of need for fund distribution purposes.There is a tendency to miss pockets of deprivation in affluent areas and in rural areas, where poor transport and lack of facilities can lead to isolation and social exclusion of children. Neither of these groups would necessarily by indicated by the deprivation statistics.

The principle should be to prioritise funding according to children's need for the full range of play experience as described above. Local grants should go to projects which can show that they fill particular gaps in the range of play opportunities available to a group of children - the more elements missing from their range of play experience the higher the priority.

While we do not wish to nominate particular types of provision (or particular age groups) which should be eligible for support, the NOF programme should recognise the unmet need for free play in physically challenging environments and in the natural environment, and for free open access play provision which acts as a valuable neighbourhood resource, able to accomodate sibling and friendship groups and support informal carers. The NOF programme should support provision which meets these needs. Adventure playgrounds are one tested model of this sort of provision.

No Priorities

Comments:

PLAYLINK agrees that a range of play opportunities for children near home is an important priority, given that what counts as near home varies with the age of children and the nature of the journeys they have to make to access these opportunities.

It is important also to recognise what constitutes a play opportunity and that it might be provided by amending policies which prevent children's use of shared public space near their home for play.

Equally, it is important not to be prescriptive. There is a balance to be struck between easily accessible local play opportunities for daily use and the potentially more unusual/exciting (expensive) range of landscaping, equipment and facilities that can be offered in 'destination' play provision.

The answer to the question 'How is this group of children to access the full range of play experiences?' is likely to be a mix of local and destination play provision and opportunities, and may in some cases require mobile or other specialist facilities and services

Comments:

We see the major problem as finding an infrastructure to support local distribution that is both universal, in order to ensure that children in areas which currently lack play provision and expertise are not further disadvantged, and has a focus on children and a partnership approach.

We are concerned that while local authorities could meet the criterion of being universal across the country, making them responsible for distribution of the NOF funds will unavoidably bring them into conflicts of interest on the issue of additionality.

We consider that the Children's Fund could offer an appropriate national infrastructure either for identifying local play partnerships for distribution or for distributing direct to local projects. By the time the NOF £200m is rolled out. local Children Fund Managers should have good knowledge of local services and provision for children and a culture of working with and building on existing groups, adding value to a range of other initiatives.

Locating distribution with Children's Fund offices should minimise draw down on the NOF fund for delivery mechanisms and maximise the chances for consistent implementation of the common framework of principles. We recognise that experience of the Chidren Fund in relation to play has been very mixed. While some Children Fund Managers have recognised and supported play, this is by no means universal. Therefore, central to this approach would be the appointment of local NOF programme managers specifically charged with responsibility for the local play programme. They would be hosted by the Children Fund and recruited for their knowledge and understanding of play and/or receive training or consultancy support on play criteria. Their role would be to promote the programme, generate and support applications and provide ongoing support as the funded projects developed. The NOF programme should be informed, but not bound, by the Children Fund's age range of 5-13.

We believe that using the Children's Fund infrastructure to support distribution of the fund could lead to creative, cost effective and practical results for children and communities. Bringing play expertise and activity within local Children Fund offices should raise the profile and understanding of play and could have a positive impact on the sustainability of projects at the end of NOF funding.

We appreciate that the basis of allocation of funds to Children Fund areas would be problematic. One way might be a formula which provides an initial basic allocation per capita and allows for further allocations in year two on the basis of applications which demonstrate plans/projects to address high degrees of need for play opportunities.

No Priorities

Comments:

PLAYLINK does not see this as a major capital spending programme partly because £200m could easily be swallowed up in a few capital projects and partly because a focus on neighbourhood play opportunities and linking with other initiatives suggests play opportunities of all kinds could be more effectively provided through add ons to other services, rethinking how children might be allowed to use public space and programmes/projects to meet particular needs.

It is important that this NOF programme is not seen primarily as a source of funds to renovate and build more fixed equipment playgrounds though they should not be excluded. It should be used as a major opportunity for communities and professionals concerned with children and play to think and plan creatively for play in their localities.

In practice, the balance between capital and revenue funding should be for local determination. Applicants should be able to show how their proposed project builds on /fits into other local funding opportunities for play or adds play value to existing facilities and services for children and families.

This approach will require raising the profile, and disseminating a common professional understanding, of play as not only intrisically valuable but also a major contributor to children's health, development and well being. The targets for promotion would be local authorities, EYDCPs, schools, PCTs and other potential service delivery partners. Parents, as gatekeepers for their children's access to services and provision, should also be targeted. The NOF Better Play programme provides an example.of using a national framework of criteria relating to children and play, based on Best Play. We propose a similar framework of criteria be attached to this fund.

Comments:

We have indicated some of PLAYLINK's thinking on this in answer to questions 3, 4 and 6.

In addition, local authorities will need to create their own frameworks of policy and strategy for planning local play services, play provision and informal play opportunities. Fewer than 4 in 10 currently have play policies or strategies according the CPC research referenced in 'Making the Case for Play'. (see PLAYLINK's 'Play as Culture' for further discussion of local authority play policies.)

A model has been developed as a performance indicator, BVPI 115, already available to local authorities through the Audit Commission/IDeA local library of voluntary PIs. Play policies and strategies can be developed as stand alone service frameworks or as part of wider community, cultural or green space strategies or of local delivery of other national Government initiatives such as neighbourhood renewal.

Local strategic partnerships, which now own community strategies, have the potential to contribute to the development of play opportunities though their capacity to do so effectively will depend on how they are structured locally. Those with a balanced representation as between the local authority and the community, and particularly those with working groups focused specifically on children, are likely to be more effective in identifying and prioritising children's needs and wishes.

Comments:

These comments follow from points made in response to question 7.

It should be part of the role of the local NOF fund managers to promote NOF project links to other local initiatives in order to contribute to joint planning, common criteria for quality, cost effectiveness and sustainability. It will be important for the NOF programme to recognise that this work of capacity building, information dissemination and promoting co-ordination of services and pooled funding has resource implications.

We are concerned that reliance may be placed on local/community partnerships to deliver this programme beyond their capacity to sustain it. Success depends heavily on building trusted relationships between potential partners and negotiating conflicts of local or professional interest or different professional cultures. While the implications for a step change in approaches to joint working and for long term sustainability would be good, it should be recognised that it will take time and resources to establish the groundwork.

The situation will be both informed and complicated by the number of other initiatives now requiring 'joined up' thinking and working and depending on the energetic participation of the community.

Yes

Comments:

In PLAYLINK's view, this should be a matter for local discretion provided certain common criteria are met. We do not think that the NOF programme itself should have a national sponsorship tie in. However, local commercial enterprises often have a policy of supporting projects, frequently chosen by their employees. The support can be either in cash or in kind and is very beneficial both in resourcing the project and in promoting supportive links in the community.

The criteria should be:

1. the project itself meets the criteria in relation to children and play

2. the project itself, any of its equipment or buildings are not branded with a commercial name

3. the sponsor doesn't constrain the policy or practice of the project or prevent other sponsors from supporting it.

Having said this, we do not see commercial sponsorship as a significant altrernative source of funding for the purposes of sustainability.

Comments:

PLAYLINK suggests the following as possible

1. Ring fence some funding to evaluate projects with respect both to outcomes for children, including accessibility and inclusivity, and to the effectiveness of processes eg establishing play criteria, creating and implementing the design brief, contribution of joint planning and pooled budgets, community participation, sustainability plans. Produce publishable materials from the evaluations.

2. Individual projects to undertake to share experience as a condition of grant eg by presenting on their progress at NOF fund seminars/workshops, providing written and visual materials, participating in national promotional events, being willing to accept visitors and provide advice based on their expereince. Presentations should include participation by children who use the projects.

3. Local NOF fund managers to have an explicit role in facilitating local networking to support dissemination of good practice

4. Create a professional support network of NOF fund managers to share examples of good practice nationally and liaise with national policy, practice and development agencies for dissemination.

Comments:

PLAYLINK has worked with a number of organisations over recent years to ensure that the tools available for playwork training, and for quality assessment and assurance in play settings, are based on a consistent set of values, principles and assumptions in respect of children and play. The baseline document for this has been 'Best Play..'

It is our intention to continue to work on maintaining and building on this consistency. For example, it will be important to ensure that the quality criteria for play in the Ofsted regulatory system for daycare reflect the same values, principles and assumptions when the national standards are reviewed this spring.

Our approach to all benchmarks, standards and quality assurance tools for play is governed by this principle of consistency with Best Play.

Comments:

PLAYLINK has been, and is, very willing to be helpful in sharing examples of good practice but would need to know the purposes for which particular examples are wanted in order to make useful suggestions.

Comments:

See answers to previous questions, principally 5 and 8.

Comments:

See answer to question 5.

Job descriptions for NOF fund managers and for project workers should require demonstrable understanding of the Best Play principles, assumptions and values and their implications for working with children in play settings and creating environments that facilitate play. Those with responsibility for recruitment and selection should themselves be similarly qualified or have access to play expertise for advice, inclusion on selection panels etc.

Given the recent history of recruitment to policy and senior posts in the play sector, we are concerned about the supply of potential candidates for these posts. This play expertise is essential to ensure that the new NOF fund is used to build on existing good practice in the play sector and it may be necessary for NOF to draw on specialist training and consultancy advice for the fund distributors as has happened in the case of other NOF funding for play.

No Priorities

Comments:

PLAYLINK is not convinced that 'innovation' is a helpful concept in this context.

As set out in answers to earlier questions, we believe that the principle should be how the accepted criteria with respect to children and play are carried into practice in local projects in a way that best suits the local situation and need. It is for the local applicants to make their case in those terms.

Because the flexible, local approach we are suggesting will allow for a variety of differenct linkages with existing services and provision for children and families, and for a different approach to the use of public spaces, we believe there will in fact be a variety of unique projects applying for funding.

However, innovation itself should not be a criterion. It should be recognised that with the current low level of provision, what is tried and tested in one area, such as adventure playgrounds in some London boroughs, may be unheard of elsewhere in the country and therefore be an innovation there.

One aim of the current NOF Better Play programme is to develop and disseminate good practice in providing play opportunties. It would be illogical if applicants to the the new NOF fund were disqualified from drawing on this on the grounds that it would not be innovative.

Comments:

See our response to question 10

Outcomes for children should be evaluated against 'Best Play' criteria and the principles of inclusivity developed by the NOF Better Play programme.

Comments:

We are grateful for the opportunity to comment more widely on both the new NOF fund and the Play Review. Taken together they are exciting intiatives with the potential to make a step change in public provision for children's play. A number of important points are raised in the Consultation Paper. PLAYLINK's views on these points are set out in the 6 sections below (including continuation sheet atached)

1. We fully endorse section 4.3 on safety. The new NOF programme should build into its criteria for funding the recent position statement by the Play Safety Forum, 'Managing Risk in Play Provision'.

2.1 There will be significant learning from the Better Play programme on the issues of both access and inclusivity. In particular, the final year of the programme is restricted to projects to promote the inclusion of disabled children. It has been recognised that in exceptional cases, it may be right to fund provision that caters exclusively for disabled children simply to level the playing field in terms of their access to play experience. However, the guiding principle should be that all play provision and services should aim for inclusivity. The aim of segregated provision should be to build confidence and experience so that disabled children can participate in mainstream inclusive services and these services can welcome disabled children appropriately. Segregated projects that seek funding from the new NOF fund should be able to show how they will meet both aspects of this aim.

2.2 Similarly, while there may be a demand for play provision that is segregated by minority cultural, religious or ethnic group, also on the basis of levelling up access to play experiences, we believe it is important to decrease the invisibility of these children in society in general and in mainstram play provision in particular. The fostering of understanding and tolerance required by inclusion enriches the play expereince of all.

3.1 In response to section 4.7 on design, we fully endorse the design based approach. We note that there is currently a shortage of expertise in this field and suggest there be an element in the NOF fund specifically to address this, for example through pilot training and/or a design competition.

3.2 We also endorse the principle of children's participation in designing, developing and running their local play project. It is worth noting however that there has been a great deal of consultation with children about their general preferences in relation to provision for their play and free time and the findings are significantly consistent (cf CPC research referenced in 'Making the Case for Play' ). Children might legitimately feel that it is time the authorities stopped asking these questions and started listening and responding to their answers. Surveys and questionnaires have limited use for a number of reasons which are well documented. A commitment to children's participation should be based on willingness to enter into meaningful dialogue with them over time, helping to extend their experience, inspiring them about what might be possible and responding to their messages.

4. We have made some reference in previous comments to sustainability based on bedding play provision into a series of other initiatives with other funding sources. In addition it would be helpful if the NOF fund distributors could encourage applicants to think, where relevant, about the future of their project beyond the funding for which they are applying. The NOF programme should recognise in principle that additional capacity to plan for sustainability is a legitimate and desirable element of an application to the fund.

5. It is not clear what is meant by the statement in section 4.10 that 'Improvements to play opportunities will need to be planned so that they have the maximum impact'. Local planning should be informed by play criteria and a flexible approach to how play experiences and opportunities can be delivered locally, as outlined in our answers to previous questions. Planning should flow from the local authority's play policy and strategy which is drawn up to reflect and contribute to a specific mix of local initiatives as indicated in BVPI 115.

6. WIDER ISSUES FOR THE PLAY REVIEW

6.1 Although the response form is directed towards the new NOF fund for play, the very well argued and comprehensive Consultation Paper hints at wider implications for the play sector. The new fund will not come on stream until 2005, about a year after the current DCMS contracts for supporting the play sector are due to end. It would be illogical not to give some consideration to the background against which the new fund will be delivered and the sources of, and structures for, support for both the fund distributors and play providers in the longer term.

6.2 The Children's Play Council document 'Making the Case for Play' is still on the table with DCMS awaiting a response which we would expect later on this year. It makes a number of recommendations which are relevant here and which PLAYLINK supports and would wish to participate in implementing.

6.3 In particular, we support the recommendation on strategic development (recommendation 37) which calls for the development of a national strategy for play. As a prerequisite to that, we urge the Government to develop a framework policy statement setting out its commitment to basic principles for the delivery of play opportunities based on children's rights, needs and wishes and a statement of its understanding of the benefits of play.

6.4 We also support the recommendation (52) for a national agency for play. We believe that there would be considerable advantages to locating a number of different roles such as strategic policy and research, practice development, evaluation, and information dissemination together in one place. The benefits would include the synergy between these aspects of infrastructure support for the sector, the cost effectiveness of shared premises and resources and the capacity to sustain forums such as the Children's Play Policy Forum and the Play Safety Forum. We believe that Government should fund such an agency's direct and indirect support work, its governance and work on its own organisational development (sometimes called core costs) but that it should be independently established to enable it to raise funds for projects.

6.5 In such poorly resourced services for which there is no statutory framework, there is always a significant problem of additionality in the distribution of Lottery funds. We agree with the principle in recommendation 50 that there should be 'an urgent and comprehensive review' of national funding for play, initially to establish a baseline before the new NOF fund takes off. We recognise that the complexity of the sources and structure of funding for play make it difficult to collect this information and that it is likely to become more complicated as the possible sources multiply (cf Appendices 3 and 4 of 'Making the Case for Play' for lists of programmes impacting on play and funds being accessed for play in 2002). However, without this information and a funding strategy to follow, children's access to essential play opportunities will remain a haphazard and unfair geographical lottery and minority groups who are currently 'invisible' in provision will continue to be neglected.