Examination of Witnesses (Questions 66-79)|
TUESDAY 16 OCTOBER 2001
66. Can I welcome you. Can I ask you to identify
yourselves for the record. And I am not sure whether anyone wants
to make an opening statement, or whether you are happy to go into
(Mr Ellis) Thank you, Chairman. I would like to say
a few words, but first if I might introduce myself. I am Peter
Ellis, Head of the Planning Policies Division in the Planning
Directorate at the DTLR. On my immediate right is David Wilkes,
who heads the team responsible for the emerging PPG. And on my
far right is Peter Matthew, based in the Department's Urban Policy
Unit, and Peter is here today as Secretary of the Green Spaces
Task Force. Could I turn to my colleague, Philippa Drew, to introduce
her team, from DCMS.
(Ms Drew) I am Philippa Drew. I am the Director for
Education, Training, Arts & Sport in the Department for Culture,
Media and Sport.
(Mr Mackenzie) Niall Mackenzie, from the Sport and
Recreation Division of the DCMS.
67. Thank you. Does anyone want to say a few
words, to start with?
(Mr Ellis) Just a few words, if I might, Chairman.
You already have the Department's memorandum, which is actually
focusing the content of PPG onto the main themes of your inquiry,
but in the light of this morning's discussion perhaps I could
just underline a couple of things. Clearly, the PPG is of fundamental
importance; sport, open space and recreation all contribute to
people's quality of life, and it is that quality of life we actually
take as our starting-point in the PPG. PPG17 is guidance for the
land use planning system on planning issues relating to those
critical issues. It is concerned with land use planning's contribution
to meeting a diversity of recreational needs, from formal, organised
sport through to the enjoyment of local open space and the countryside.
It is not guidance on how to prepare a corporate strategy on sport
or open space, or recreation. It is about what land use planning
can, and what land use planning should, contribute to a community's
well-being in these areas. Clearly, it is absolutely vital that
we get the PPG as right as we can. We accompanied the consultation
by a series of questions. We asked specific questions on scope,
workability and on particular issues which were key to the direction
of the PPG. What is quite clear from the responses we have had,
and from the comments made to you this morning, is that not everyone
actually thinks we have got it entirely right. Now that is the
great advantage of consultation, we test the ideas, we test the
processes, before it is actually implemented. So we very much
welcome, Chairman, your Committee's inquiry and we look forward
to having your report on how we can improve the PPG.
68. Thank you very much for that. The only thing
just worrying me slightly, because you almost implied that if
you had a football pitch which was down in the planning proposals
as a football pitch, that would be perfectly alright, even if
it was in such a poor state that no-one could play football on
(Mr Ellis) No, I do not think that is quite right.
Certainly, it was not what I was wanting to imply, Chairman. We
were coming basically at the question of assessing a community's
needs for sport, open space; for that particular football pitch.
We have a fair amount of guidance in the PPG on that issue; it
is saying that we are not just interested in quantity but in quality
in carrying out the assessments of need and what a community should
actually be planning for. We underline the need to think about
quality, as well as count beans, because, as you were intimating,
there is no point in having a facility or that potential opportunity
if no-one is actually picking it up or it is not capable of being
used. So it is actually important that when local planning authorities
are preparing their plans they are actually assessing need, they
are thinking of qualityusabilityas well as just
ticking the presence of that facility.
69. Let us put in one thing there seems to be
general agreement about then, that there is quite a lot of disagreement
about the proposals that you have produced so far. Have you already
decided to take on board some of those criticisms; if so, which
have you decided to take on board? And are you genuinely listening
now to what else is being said?
(Mr Ellis) Taking the batting order in
reverse, yes. I think what I would actually say at the outset
is that there is a lot of general support for what PPG17 is looking
to achieve, there is general support for the fact that we put
planning for sport, open space, recreation, at the heart of the
Government's policies for sustainable development, urban renaissance
and a thriving countryside. And I think there is general support
for the fact that, in planning for those important areas, we are
looking at all aspects of sustainable development, economic growththe
economic health of the communitysocial inclusion and protecting
our environment. Now I think the answer to your second question
is, yes, we accept there is concern about ambiguity in parts of
the drafting, including a greater wish for clarity in some of
the definitions we use. So, in the light of those sorts of comments,
I am not wanting to sit here before you today and say the PPG
is perfect in all aspects, clearly, it is not; we are working
on that. That said, I think it is also fair to say that some of
the adverse comment about the PPG is special-pleading from interest
groups. We cannot hope to cover all the interests of particular
groups in the PPG, it would become like a catalogue. The policy
which we are trying to actually convey to local authorities would
be lost. What the PPG does do is underline the importance of all
sport, open space and recreation to the well-being of communities.
And in the processes we actually set out in the PPG we underline
that they should deliver across the board. The other thing, if
I might be mischievous, is that what we do notice is that we get
opposing viewpoints put to us in commenting on the PPG. Those
who actually want to emphasise planning for sport say we have
not quite emphasised that sufficiently. Those who are wanting
to actually underline the importance of open space say the PPG
actually fails in that aspect. So, in short, yes, we appreciate
there is concern about some of the drafting. We want to ensure
that in the document actually delivers effectively on the ground
the policy that is set out in the PPG.
70. Perhaps we can go through those points,
because there have been some specific criticisms, and perhaps
DCMS can come in and deal with one or two of them as well. One
is that you said that some people feel there is too much bias
towards sport and some people feel there is not enough concentration
on it, but perhaps there has been more evidence given that the
guidance so far has been more dominated by sporting interests,
and the corollary to that is a feeling that perhaps there is not
really any adequate definition of open space in the guidance,
and therefore that leads to real difficulties and a lack of proper
concentration on that issue. And, finally, something the DCMS
might want to pick up on, a belief that there are inherent contradictions
in trying to deal through one set of guidance with what are sometimes
very major sporting developments, very major additions to the
built environment, at the same time as you are dealing with open
space, on which there might be a planning proposal to put that
major sporting development. You now have inherent conflicts which
simply are not dealt with in the current guidance that you are
(Mr Ellis) I think, adding extra emphasis on open
space to the document has brought some complications. But it is
essential, in my opinion, that the sport, open space and recreation
needs of a community are considered together. Now, clearly, there
are the sorts of problems of considering them in the one guidance
that we have heard this morning and in the response to the consultation.
But the risk of separating them would be greater. It is essential
that local authorities preparing their development plan strategies
are looking at their communities' needs for these issues in the
round, so that the strategy their plan then espouses is delivering
in the round on these matters, rather than actually leaving the
sort of conflict you are describing to be resolved on the back
of a planning application, where people inevitably are at loggerheads
with each other. So it is essential that we look at demands, that
we look at needs.
71. I am sorry, I do not really accept that.
There is (Poole ?) Point, a piece of land in my constituency,
people consider it to be an open space, it is actually zoned on
the UDP for leisure; currently, it is used for leisure because
football games happen on there on a Saturday afternoon and a Sunday
morning, but the people who live around the area are basically
content, because they have got a green field for most of the week
with a few footballers on it on Saturday and Sunday. A proposal
is about to come in for a major planning application for a sports
centre and swimming-pool; that changes the nature of that land
completely. It is therefore through the planning application that
the use of that land and its impact on the local population will
be dealt with, not through the UDP process but through the specific
planning application that it is still leisure use; and that is
a confusion in there which I do not think anything is done to
resolve in this new, revised guidance?
(Mr Ellis) If I might take us back to the development
plan, because I understand entirely the sort of situation you
are describing, which is generic, not just on that particular
proposal. The key to ensuring that a decision is taken in the
best interests of the community in the round is to ensure the
planning strategy is right in the first place. And that is where
the thorough assessment of need, a thorough assessment of what
the community actually requires, against the land resources in
that community, is so important. The plan is critical to the sensible
resolution of that sort of proposal. In the absence of a sensible
plan, I agree with you entirely, it makes the satisfactory outcome
in the interests of the community much harder to achieve. Which
is why, in the PPG, we are actually saying to local planning authorities,
"Get your forward planning homework right in the first place,
please, because that ensures you will get sounder planning decisions
as an outcome."
72. So, on the unitary development planning,
that case, it should not just be marked up as open space but it
should have a footnote to it describing what sort of open space
use it should be put to?
(Mr Ellis) If the intention is, and my colleagues
will correct me if I get this wrong, Chairman, that there will
be a major, built facility on that particular open space, that
should be taken forward through the local plan, or the UDP preparation
process, to be debated properly at the inquiry; in the light of
the evidence that the local authority has assembled on need against
what the community is requiring and against the land resources
that are available to accommodate that sort of facility.
Chairman: You are pulling a face; do you want
to ask a further question?
73. I am not sure how precise the definitions
in the UDPs are to allow this to happen; if they do not distinguish
between built leisure facilities and so on?
(Mr Wilkes) They can do. A local authority can identify
a site on their development plan which clearly identifies that
site as going to be developed for a particular use, and that could
be a sports facility of some sort.
74. So a truly UDP process then is the advice
from the Department, or local authorities in producing their plans
should distinguish between leisure with a significant built element
to it, informal leisure and open space without any informal leisure
of any kind; is this what you are suggesting?
(Mr Ellis) What the plan should do is identify proposals
the local authority are advocating for particular pieces of land.
The plan should highlight, it should protect, those areas of open
space where it does not want to see built facilities. The key
to the resolution of the sort of conflict you are describing is
clear forward planning, in the context of the UDP, or the local
plan. So people then, the local community, can say, I'm sorry,
we don't think you've got that balance right; our desire for this
particular piece of open space is . . . "whatever";
but the key is proper forward planning based on proper assessment.
75. You are well aware the Urban Green Spaces
Task Force is supposed to influence the revision of the planning
guidance, and you are also well aware that your memorandum intends
to produce a final version of the guidance before the Task Force
actually concludes its work. That is not joined-up government,
is it, really?
(Mr Ellis) The joined-upness is that we are kept closely
in touch and seek to be kept closely in touch with the working
of the Task Force. We are looking to ensure that the work the
Task Force is going to deliver fully informs the work on the PPG.
76. But how can you ensure that, if you have
not actually got the final report at the point at which you submit
the final PPG?
(Mr Ellis) Can you talk just a bit about your Task
(Mr Matthew) I think there are two things there, Chair.
The Task Force, first of all, was set up after the PPG17 revision
process commenced, and I think what we have had to consider, in
carrying forward the work of the Task Force, is how both the work
of the Task Force integrates with the work that is going on on
the planning side, and, I think, first of all, I am on the working
group with my planning colleagues, who are actually looking at
the PPG; so, in that context, I am, in a sense, providing that
link with our planning colleagues and the work of the Task Force.
77. But it is simply an informal link, is it
(Mr Matthew) Well, I will continue. I think there
are two things that we need to consider. At the time of consultation,
the Task Force did consider the PPG17 issues, and representation
was made to the planning team. The second thing I would say is
that a working group of the Task Force has been set up to specifically
look at the whole question of how we go about improving the planning,
design, management and maintenance of green spaces. And, one of
the things I do want to say, I do not think we are actually operating
this on the basis that we will wait for final reports; there is
the question of trying to track the progress of the work and pick
up the emerging issues and feeding them in in that way. So I do
not think necessarily it is a question of waiting for final reports.
78. What would be the disadvantage of waiting
for the final report?
(Mr Ellis) These things are never actually easy to
come to a completely right view on, because the world moves on
in many ways. There are obviously important contributions to PPG17,
such as that of the Task Force. What we need to ensure is that
as soon as we can have a robust piece of planning guidance we
get it out into the wider world to ensure that these important
issues that we have all touched on this morning are being dealt
with by local planning authorities properly. So there is a balance
to be struck between ensuring we are properly informed and getting
the guidance out as soon as we reasonably can. Hence why I underline
the working relationship we have with the Task Force to ensure
we are understanding what is exactly emerging from their work.
If it seems, broadly speaking, the PPG, as emerging, is in the
right territory and getting it right then we are going to be comfortable.
If it actually seems that is not going to be the case then we
will have to actually review that at that time.
79. Mr Matthew, you said you made representations;
were they successful representations?
(Mr Matthew) I think my planning colleagues have as
good an understanding as myself. But I think my planning colleagues
at this stage are aware that I have got a bundle of issues, which
is coming via the Task Force side, which I will want to actually
take up with them in the revision to the draft. And I think the
key point for me, and I think they will probably agree, is that
I do not think there is a closed door, in terms of the issues
and in terms of taking forward a revised draft. And, certainly,
we have had a very close working relationship in ensuring that
those issues are actually filtered through, and I am quite confident
that that will happen.