Select Committee on Transport, Local Government and the Regions Minutes of Evidence

Examination of Witnesses (Questions 1-19)




  1. This is the first session of the Select Committee's inquiry into the draft PPG17, Sport, Open Space and Recreation. Can I begin by thanking all those people who sent in a memorandum to us; the memoranda are now published in this House of Commons document, and probably, for most of you, more usefully, they are available on the House of Commons web page. So not only can you see again what you sent in as evidence but you can see what other people sent in, and we hope that will encourage a discussion outside the Committee; in some cases people may even want to write in commenting on other people's memoranda, and we would welcome that. This morning can I welcome the four of you and ask you to identify yourselves, for the record, please?

  (Sir Neil Cossons) I am Neil Cossons, Chairman of English Heritage.
  (Mr West) Jeff West, Director, Conservation Management, English Heritage.
  (Mr Coleman) David Coleman, Director of the Countryside Agency.
  (Dr Harding) Stewart Harding. I lead for the Countryside Agency on parks and open spaces.

  2. Do any of you want to say anything by way of introduction, or are you happy for us to go straight to questions?
  (Sir Neil Cossons) I am happy, Chairman.
  (Mr Coleman) We can go straight on, Chairman.

Mr Cummings

  3. I understand that perhaps you are all quite pleased—and I am directing this question, basically, to the Countryside Agency, but, the others, please come in—that open space has been made the subject of planning policy guidance. Do you think that sufficient open space is treated successfully and clearly in the new PPG?
  (Mr Coleman) No, I think it is inadequately treated. I think we welcome many of the specific proposals, and I can come on to the detail if you wish, but standing back and taking the PPG as a whole we do not think it deals adequately with open spaces. There is clearly a major problem in the range of recreation and resource and site and that huge range of material that it attempts to cover, but we believe it does not succeed in covering it adequately. And I suppose, if I were to pick on one reason for that, it is because it is far too driven by the activity, whether it is recreation or sport, or whatever, and that leads to great difficulties, and ultimately, I believe, inadequacy, in dealing with the more resource-based issues that arise in relation to open spaces.
  (Sir Neil Cossons) And we have the same view, that it is inadequately dealt with in the framework of the PPG. The nature of open spaces is so diverse, in terms of the particular qualities relating to them, that to handle them within the framework of a PPG is particularly complicated anyway. So, although the PPG is in one sense the right place to have a strategic overview of how open space should be dealt with, for the reasons just set out that tends not to be the case, and therefore open space falls through the net.
  (Dr Harding) Could I add to that. If, like me, you have got a long background in the promotion of parks and open space, the PPG actually strikes a very discordant note in the way it presents open space issues. My view of it is, I know how the PPG was conceived and I know how it evolved from earlier PPGs, but in terms of public interest and public involvement there is no doubt that open space is a much more important issue to more people than sport, for example, and, the way the PPG is presented, it tries to make open space a subset, I think, of sport and recreation. And I think therein lies the major difficulty with the way the PPG has been drafted, that open space is an extremely important topic on its own, and to have it tacked on to the end of sport and recreation issues I think misses the point. And you can appreciate what I am trying to say if you turn the title of the PPG round, to reflect public interest, to say that the PPG maybe should be called Open Space, Recreation and Sport. Open space is a resource, sport and recreation are activities, and when you look at it like that and say open space, recreation, sport, you do have to ask the question, well, why sport, why not open space, recreation and play, or open space, recreation and music, or open space, recreation and events; because these are all things which open space does, and the open space does it as much for those things as it does for sport. So I think that inherent flaw in the drafting actually presents all of the difficulties.

Sir Paul Beresford

  4. Looking at it from another point of view, would you not say that what you have just said is really a poor reflection on this country? Here we are, where we are currently, the All Blacks always beat England, or almost always, Australia manages better Olympics; the southern hemisphere's attitude to sports is reflected in their successes. If you look at the population of those nations and look at the population of this nation, if you look at our sport success, what you have said is a very sad reflection, and perhaps we ought to have a different attitude towards sport, and therefore a better use of the open spaces that are available?
  (Mr Coleman) If I could answer that. There is no question about sport being important and sport raising many important planning issues that need to be dealt with in a PPG; we were addressing the specific point about why is open space dealt with badly in this PPG, and that is about structure, we can come on to what some of the solutions might be in a minute, but that is about structure and confusion in the way which it is dealt with.

Mr Cummings

  5. Do you think that there exists an adequate methodology to plan for open spaces and informal recreation which the PPG could promote?
  (Mr Coleman) Perhaps I could ask Dr Harding to comment on that; it comes from all of his experience.
  (Dr Harding) I think we do need a methodology, because I think the other major problem with the PPG is that it is not contextualised in terms of the problems facing parts of open space and recreation space; and local authorities need as much guidance as possible on how to do better with their parks and open spaces. We have got the old standards which are largely seen as old-fashioned and fairly meaningless. I think the Agency would prefer quite a loose definition but something which appreciated in a wider way people's use of open space, so that we would like a standard which said people should have access at no more than, say, 500 metres from high quality open space, and you could bring into that view the time it takes to get there, or the difficulty it takes to get there, or whether the open space is actually safe and attractive when you do get there.


  6. Is that realistic? There is no point putting something into planning guidance that is not realistic. You think, really, that distance from people's home there should be some open space is realistic?
  (Dr Harding) Clearly, it is an idea, but I do not see any problem with the PPG being aspirational, in that sense. If you try to be realistic, in your sense, you will end up with the lowest common denominator, that which is achievable, and I do not think that serves the purpose either.

Mr Cummings

  7. Do you believe that there exists an adequate methodology, is that what you are saying?
  (Dr Harding) There is an awful lot of work to be done on this. There could be an adequate methodology, but it needs an awful lot of work by an awful lot of different agencies to produce it, and in some ways the draft PPG is pie in the sky in the way that it talks about we need this, that or the other, when we actually know that local authorities are having great difficulty even managing and delivering what they have got. Somebody needs to do a methodology, somebody needs to make definitions of parks and open spaces, and somebody needs to define standards; at the moment there is nobody there to do that job.
  (Mr Coleman) A distinction it might be helpful to make is between standards and benchmarks; standards may be the wrong word, because of the variability and the diversity that is needed in this situation, but certainly we think there is enormous value in the Government leading, and a PPG is a good place to do it, in establishing benchmarks, what would be good provision, what would be medium provision, what would be poor provision. Now you could describe it as a standard or a benchmark, but it would give a framework within which local authorities could then plan.

Ms King

  8. Sorry, I was so interested in following up the little exchange that just took place, and I think it does lead on to what I was going to ask about, which is about formal open space strategies; and whilst I come from the point of view that I very much want us to improve our sporting standards, and I am a bit of a sports fanatic myself, I have to say that most of my constituents write to me wanting open space, not necessarily formal sporting provision. Given that, I certainly think we need more formal open space strategies. I am directing this remark to English Heritage. We were slightly surprised to see that you appear to come out against such formal strategies, and, as we received a number of memoranda that do the opposite, although we understand what you are saying about strategy overload, and, indeed, we were hearing earlier how local authorities are actually, what was the term, 'overstrategising and underdelivering'. We do think that if there is to be a rational approach to open space provision it does need to be within a strategic framework; would you not agree?
  (Sir Neil Cossons) We would agree; and I think our anxiety was that to have a free-standing open space strategy which was not locked into the wider spatial development strategy that a local authority would be expecting to develop would actually be to lose the game. There needs to be strategic thinking for the protection of and provision of open space within local authority areas, and within the context of a PPG, which is a planning document, it therefore needs to be locked into the wider issues of planning development and spatial strategy.

  9. But do you think that developing these formal strategies should be mandatory?
  (Sir Neil Cossons) Parks and open spaces are not a mandatory responsibility of a local authority, but they exist and local authorities have responsibilities for them; and one of the difficulties, I think, is that there is no natural champion within a local authority for open space. If you look at the way in which local authorities care for their open spaces, open spaces fall within a wide variety of departments; there is no common formula or pattern across the country. That indicates, to me, that local authorities do not know what to do with their public open space; because they are not a statutory responsibility it is easy for them to fall off the end of the shelf when other funding and strategic priorities are pressing. And you can see that, I think, in the decline in the funding that local authorities have spent on open spaces over the last 20 years, or so.

  10. If you are correct, that local authorities do not really know what they are doing with their open space, then is it not all the more important that local authorities themselves are actually forced to try to come up with a strategy, as opposed to, say, relying on what you were talking about earlier, which was benchmarking; although there is a place for that, surely it is not sufficient?
  (Sir Neil Cossons) It seems to me that there are two issues. One is, within the framework of a PPG, that is a planning framework and public open space should have a strategic place in the planning thinking of a local authority. The other side of that coin is that local authorities properly look after the public spaces for which they have responsibilities, and that implies benchmarking, standard-setting and some mechanism whereby local authorities can then be assessed in their performance as guardians of public open space. It is something to which, for example, the Audit Commission could take note, either through best value or their other procedures.

Dr Pugh

  11. Could I press you a little bit on this. What you seem to be saying is that a strategy is a necessary but not a sufficient condition of the good development of open spaces, and you are fairly diffident about strategies. Now, is the reason that you have a degree of cynicism about the way in which strategies may be related to resources, or is your view, alternatively, not that but that the strategy itself may be too prescriptive and too hampering in what it may achieve?
  (Sir Neil Cossons) The need for a strategy within the planning process, it seems to me, is self-evident, as long as that strategy is locked into the wider spatial development strategies which guide that planning process; and there ought perhaps to be presumptions against development which will protect areas of public open space, and those presumptions should be established and set out within the overall planning strategy for a local authority. But there is a discontinuity between that strategic desire to define and, in theory, protect public open space and the technical ability of the local authority to deliver the sorts of quality of protection that is necessary.

  12. It is the scope of the strategy that is the problem?
  (Mr West) If I may. We are absolutely clear, I think, that there needs to be a strategic approach to open space taken by local authorities. The problem at the moment is that local authorities are being asked to prepare, or help facilitate, so many different strategies, to a large number of which open space is absolutely critical, whether it is the community strategies that are being prepared by Local Strategic Partnerships, whether it is Local Plans, or whatever will emerge from the Planning Green Paper, later this year, to replace the current Local Plan process. Open space is critical to all of these, and a strategic approach needs to be taken. The critical thing is that they be joined up. We do not want a free-standing strategy that is just put on the shelf. It needs to be embedded in the whole range of thinking about local areas.

Mr Cummings

  13. You suggest in your memorandum that PPG17 fails to serve as "one of the keys to the urban renaissance promoted by the Urban White Paper". Would you like to tell the Committee why you think this, and expand upon why you believe this has been "a missed opportunity"?
  (Sir Neil Cossons) Yes. I think the PPG17 as a guideline within which we can contemplate public open space fails to establish the broad generic case for open space, and I come back to the point made earlier, that it seems to me that we are looking at public open space as the first order issue here, and the second order issues are the nature of the values that attach to those open spaces in the eyes of the communities they serve and the uses to which they are put, whether they are recreational or sport, or whatever. And it seems to me that we do need to turn the argument over and recognise that public open space is a good in its own right, that it has various qualities attaching to that good, and that needs to be set out as a central plank of our approach to public open spaces within the planning system.
  (Dr Harding) I think the problem is this dismal expression 'open space' which sounds like an absence of anything, and when that expression gets embedded into planning jargon, why do we not call them something much more positive.

  14. Such as?
  (Dr Harding) I thought of this on the train today: recreational and pleasure grounds; they are positive attributes, they have positive uses and people treat them positively, given half the chance. If we call them 'open space' it sounds like they are up for grabs for anything.


  15. What does a central reservation on a dual-carriageway count as; does that count as open space, or is that part of the transport infrastructure?
  (Mr Coleman) You raise a serious point, if I can just intervene, which is that it is an example of where the PPG gets kind of part of the argument right. I cannot remember which the chapter is, but it defines informal open space, and it draws that definition extremely broadly to include historic importance, to include wildlife, but it does not deliver that throughout the whole document. So there is a recognition there that open space, as has just been pointed out, is the baseline resource, the overarching resource, but it does not follow it through in its proposals.

Christine Russell

  16. I would particularly like to ask the Countryside Agency why you believe that insufficient emphasis is placed on urban parks; what do you feel, looking at urban parks in particular, what should the guidance say?
  (Dr Harding) A tricky one. This goes back to the way the PPG was drafted. The impression given of open space, despite the definition in the footnote on the first page, is that open space is being regarded, if recreation is a subset of sport, it reads like recreation is sport for fat kids and open space is the other stuff, which is not even informal recreation. Public parks are a hugely important part of our daily life, massive numbers of visitors, five million visitors, to St James's Park; now that is exceptional, but an average, traditional, urban park in this country will have between 100,000 and 350,000 visitors a year. Now that is a huge thing. This PPG is silent on all the thousands of aspects in which urban parks contribute to the quality of our daily life. And they are still under pressure, they are under pressure from neglect, they are under pressure from underresourcing, but they are also under development pressure, too, and they are regularly being changed for the worse, and PPG does not say anything about that. So urban parks deserve a PPG almost in their own right, I would suggest.

Mr Cummings

  17. Why did you draw an analogy with St James's Park? I would have thought that could have been used as a throughway, a way through?
  (Dr Harding) It was just an example.

  18. Is it a good example though, looking at St James's Park?
  (Dr Harding) It is a park of the quality that most towns would aspire to, but it is also a park of the quality that most towns had 30 years ago.

Mrs Ellman

  19. A question to English Heritage. Specifically, how do you think that the PPG can address issues of management, maintenance and design?
  (Sir Neil Cossons) It comes back to the question of whether the PPG is the right framework within which to consider management issues. It seems to me that we can define within a PPG the qualitative need for open space, we can define the nature of the activities that define that open space, or, indeed, the particular qualities, be they ecological, to do with biodiversity, or to do with historic landscapes and buildings. One thinks, for example, of Sefton Park, in Liverpool, and Birkenhead Park, just across the water, as examples of historic parks which have encouraged similar developments all over the world; they need, therefore, to be protected as part of the wider heritage. All of that, it seems to me, is the legitimate area of a PPG. There could well be, attaching to that, however, guidance on how a local authority might look after its public open spaces; in our case, we would be interested in historic parks, in particular, with examples of good practice, and attaching to them some benchmark standards.

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