Select Committee on Transport, Local Government and the Regions Third Report


CRITICISMS OF THE REVISED PPG

8. There was a large response to the DTLR's consultation. None of those who submitted evidence or responded to the DTLR consultation disagreed with the principle of revising the PPG, and the majority commended the objectives of the revised PPG and the outcomes which it seeks.[25] However, most were highly critical of, and were very concerned about, the draft's lack of clarity.[26] Many doubted that the actual guidance would help local planning authorities meet these objectives. The Royal Town Planning Institute stated that "the draft PPG's guidance to local planning authorities (LPAs) on how they might be achieved is less than impressive" as it is too all-embracing and contains "mixed messages".[27] Without serious revision of the PPG and consideration by the Government of the criticisms that have been made, there is little chance that the guidance document will fulfil its important objective of furthering the urban renaissance. A few witnesses argued that the revision was so bad that the 1991 PPG provided better guidance.[28] DTLR Ministers, Lord Falconer and Sally Keeble, in their oral evidence to the Committee accepted many, but by no means all, of the criticisms.[29] Lord Falconer told us that the PPG showed:

"lack of clarity, insufficient joining up with other parts of the system, lack of connection with the planning gain system, insufficient involvement of the local community".[30]

9. The main failings of the revised PPG were:

—  the failure to recognise the contribution which open space makes to wider concerns such as social inclusion, health and the urban renaissance;

—  the emphasis on quantity and provision of new open space rather than on quality and enhancement of existing space; essentially, in revising this PPG the Government has not put enough stress or thinking into the role of open space and recreation in improving the quality of urban areas; for instance, it ignores hard spaces and networks of spaces;

—  the failure to respond to the need to link planning and management more closely together;

—  the inadequacy of the framework the PPG gives for planning for open space; and

—  the failure to give adequate protection to open space.

Memoranda submitted to the Committee made many other detailed criticisms. For example, four organisations with interests in water-related activities complained of the lack of guidance relating to water space and water sports.[31]

THE LINK TO WIDER CONCERNS

10. English Nature highlighted that the PPG gives:

"little recognition of the contribution that open spaces make towards bio-diversity conservation and environmental function (eg flood control, pollution amelioration); little recognition that sport and recreation can have adverse impacts on bio-diversity and other natural features..."[32]

The Countryside Agency expressed similar worries in its submission to the Committee and stated that:

"The document fails to address issues of landscape character, bio-diversity and the historic environment."[33]

The draft PPG makes some reference to wildlife. In Chapter Three it is noted that one of the functions of informal open space is to provide "havens and habitats for flora and fauna" and that it may contribute to achieving the objectives set out in "local bio-diversity action plans".[34] However, there is no prescriptive or recommended guidance in this area. Witnesses did not think that the role of open space in aiding bio-diversity and protecting wildlife had been sufficiently emphasised.

11. Most witnesses recognised the fundamental importance of sport and the role it can play in securing an urban renaissance. However, they thought that the draft concentrated too much on sport and that more recognition should be given to informal recreation as more broadly relevant to the population. A minority of park visitors use parks for formal sport, and demographically, the ageing population means there will be fewer participants in many types of active sport in future.[35] This was recognised in the 1991 PPG, which noted that:

"health related activities ... are likely to gain in popularity during the decade, while team and strength-based sports may decline".[36]

This means that informal recreational activities such as walking are likely to increase, especially if there is an attractive safe and joined up network of open space.[37] Accordingly, informal recreation should be given at least an equal weighting with sport within this PPG. At present the current draft mentions sport ten times more often than open space.[38] This led the CPRE to claim that the draft:

"Underestimates the importance of informal recreation ... which is an order of magnitude more popular than formal recreation.".[39]

Martin Doughty, Chairman of English Nature, told the Committee:

"We are not saying that the emphasis given to sport is not important, we are saying that the emphasis given to open space, in a sense, has almost been tagged onto the end of this".[40]

12. On the other hand, other witnesses thought that the role of sport in bringing about an urban renaissance had been under-emphasised. Business in Sport and Leisure commented that:

"the draft PPG 17 does not consider the wider aims of the Urban White Paper in improving the health and education of communities and reducing crime, and the contribution sport can make in this area".[41]

This was a view echoed by Sport England who claim that:

"the revised draft would lead to a diminution of the role of sport and recreation in the planning process".[42]

QUANTITY AND QUALITY

13. Witnesses' second main criticism was that the revised PPG stressed quantity rather than quality. The neglect of quality is important because of those open spaces which will exist in thirty years, probably 90 percent of them already exist.[43] There are likely to be few major new open spaces, such as parks, in urban areas because of the limited land available and because of increasing pressure for high density development. When new housing is built on existing brownfield sites in existing towns and cities in line with Government policy, residents will have to make use of those spaces and facilities which already exist.[44] One witness observed:

"scope for improving the quality of existing space is far greater and likely to be more beneficial than anything you can do in planning by adding green spaces. It is not where the emphasis should be".[45]

and

"Planning policy should be directed towards encouraging an 'urban renaissance'; this means improving the quality of the urban environment, particularly in inner-city areas where development provides little opportunity to create new open space".[46]

In many places there is ample open space, but of very poor standard. If open space is to contribute to better living environments it must be useable; if it is in a poor state, it will reduce the quality of people's living environments. Other witnesses made the point that giving priority to providing new space could lead to problems if there were inadequate resources for long term maintenance. Kit Campbell Associates' memorandum warned that the emphasis on new space is:

 "storing up long term maintenance funding problems for those local authorities which are willing to adopt and subsequently maintain new open spaces."[47]

14. While the quantity of space and the provision of new space was seen as over-emphasised, there were some other aspects which witnesses felt were not given sufficient prominence. For example, the revised PPG's approach to open space was criticised as simplistic in failing to recognise the differing types and uses of open space and the diverse needs of the population for these different types of space and facilities. It implicitly assumes that "open space" is always vegetated, but one witness noted:

"the urban renaissance is about parks, play areas and public space, including hard public spaces ... It [PPG 17] has to orient itself to that wider definition of public open space."[48]

15. Although the draft PPG notes that one of the Government's main planning objectives for sport and recreation is to create and maintain "networks of recreational facilities and open spaces",[49] it does not follow this idea through in the guidance or give an explanation of why networks of space and facilities are important. Accordingly, the importance of networks of green space is also under-emphasised. We were told:

"Unless you have a high quality set of open space networks we will not get children back in the streets playing, walking to school and so on."[50]

and

"traditionally we see open space as a series of parks or discrete spaces and I think in a more environmentally conscious era we are trying to think of open space in the city as a series of networks or corridors through which people walk or cycle safely, so the whole question of open space includes not just the discrete spaces but the streets and the ways in which you connect these things up."[51]

The development of such networks of open space is largely dependent on space that already exists.

MANAGEMENT AND MAINTENANCE

16. The third main criticism was that the management and maintenance of space and facilities has been largely ignored in the PPG, despite its importance. Effective management is a key factor in determining whether an open space is sustainable and contributes positively to a viable and high quality network. Evidence suggests that the poor management and maintenance of open space is one of the main reasons behind the decline in parks and open space.[52] The PPG needs to consider how it might improve the management of open spaces to enhance quality. One witness commented that:

"the difficulty is that planning and management has not come together as closely as it does in other countries".[53]

The problems of management and maintenance also have implications for the sustainability of open space. Jon Rouse of the Commission for Architecture and the Built Environment (CABE) warned of the:

"great danger of rushing ahead and putting all the emphasis on providing new space when, say, local authorities do not have the resources or the mechanisms to manage and maintain it properly".[54]

  17. The Government has argued that it was not the job of a planning policy document to address the problems of management and maintenance of existing space; it is for local authorities to allocate funds from their budgets for this purpose.[55] Lord Falconer said:

"planning is about determining what you do with land, whether you allow it to be developed. You can help by making decisions about the design of what is proposed to ensure that maintenance would be easy, but I do not think it is the role of the planning system to say 'That site is not maintained properly. Therefore we must intervene in some way'".[56]

18. Nobody doubts that it is the job of local authorities to maintain parks and open spaces, but, as one witness commented: "planning is a positive endeavour...".[57] In many areas planning for the future should give priority to enhancing existing space and facilities. This is especially true if we are to see higher population density in urban areas. Allowing open space and facilities to become rundown will reduce land value and undermine the urban renaissance, but supporting the urban renaissance is a self proclaimed objective of the revised PPG 17.[58]

19. The Committee recommends that the PPG be redrafted to emphasise more clearly its role in achieving an urban renaissance: by greater emphasis on:

    (a)  quality;

    (b)  the creation of a network of green spaces;

    (c)  wider uses of informal spaces, for example, to provide places for wildlife to flourish; and

    (d)  the management and maintenance of open space and facilities.

20. A number of witnesses, including the Countryside Agency, suggested that open space had been tacked on to this PPG.[59] The renaming of the PPG would reflect the importance and popularity of open space and informal recreation, and should encourage the recognition of its role in furthering the urban renaissance. The Committee recommends that the PPG be renamed "Open Space, Sport and Recreation" to give greater emphasis to open space and logically to reflect the importance of this land use.

INADEQUATE FRAMEWORK FOR PLANNING FOR OPEN SPACE

21. The most fundamental criticism of the PPG is that it fails to provide adequate process guidance. Local authorities need and want clearer guidance on the mechanisms and operation of how to plan for open space and sports facilities.[60] 144 of the 206 local authorities who responded to the DTLR consultation draft asked for this. We were told that what is needed is:

 "a clearer framework for planning authorities, developers, the community, everybody so that they can make their own judgements about issues for the future".[61]

Without this:

"you have no consistency or coherence in the types of decisions you are going to get from planning authorities".[62]

22. The recent Planning Green Paper states that the Government intends to separate policy and process guidance:

"We propose to ... separate policy guidance from practical implementation making clear the distinction between national policy which should be followed and advice which can be interpreted more flexibly".[63]

While we endorse this separation, it remains important that the main PPG sets out a clear framework that local authorities are required to follow. This is the case even if more detailed guidance is put into a companion document. As a result of the inadequacies of the revised PPG, it is unlikely to provide certainty for developers, property owners and householders, and local authorities fear that their plans and decisions will be challenged. The Committee was told that a clearer framework could be established by providing:

- definitions and a typology of space and facilities;

- clear and detailed guidance on how need should be assessed; local standards created and open space strategies prepared.

It is vitally important that the framework is clarified before the final publication of the PPG.

23. Open space is extraordinarily diverse. It can be taken to mean anything from a square, plaza, canal-sides, allotment, parks or public gardens. Clear definitions, a typology classifying different types of open space and a hierarchy ranking the types is needed. As one witness put it:

"The lack of a clearly stated and widely adopted typology of open spaces bedevils the whole issues of effective open space planning. Without it, different agencies use different terms and there can be a serious lack of clarity over both objectives and desirable outcomes."[64]

Jon Rouse of the Commission for Architecture and the Built Environment (CABE) told the Committee just how diverse a definition of open space he would like to see:

"The reality of urban open space provision should encapsulate skateboarding, street hockey, basketball courts, pocket parks, Home Zone street-side play areas, informal squares, public art installations, canopies, farmer's markets, water features, murals, temporary information kiosks, moveable trees, performance spaces, temporary ice rinks, café seating areas etcetera. etcetera.".[65]

Such definitions are fundamental to assessing the need for space and facilities and their quality and value. They also assist in identifying deficiencies, setting local standards and their application through open space strategies and development plans. To provide a more adequate framework for planning the PPG requires better definitions of "open space", "recreation" and "informal open space".[66] It is important that planning guidance is clear:

"if you are producing planning guidance which has to face legal tests in planning appeals and the like, you have to get the terminology right or you will simply be pulled apart in what tends to be a rather legalistic process".[67]

Without greater clarity in this area there is a likelihood of muddled thinking in both making policy and development control, which is neatly illustrated by the current revised draft. An example of a possible typology and hierarchy of open space can be found at Annex 2 to this Report.

24. Witnesses also thought that there was not enough guidance on how needs should be assessed and were concerned that the existing guidance would not produce clear evidence and could lead to development plans being challenged at inquiry. We were told that:

"Strategic planning is often driven not by any analysis of local needs, or even local circumstances against a background of national policy ...".[68]

Some argued that there should be a requirement for community involvement in needs assessment. Dickon Robinson, Director of the Peabody Trust, stated:

"Our experience at Peabody Trust has demonstrated that such assessment should be community-led and we would suggest that comprehensive community involvement in assessments should be required".[69]

25. An important aspect of policy guidance is how standards in respect of the type and amount of provision should be set. The DTLR memorandum notes:

"The Government has considered whether national standards should be included in the new PPG 17, but firmly believes that local assessments are a better approach to planning for sport, open space and recreation".[70]

Local standards are important because of the diverse range of conditions and needs in varying urban, sub-urban and rural areas. The National Playing Fields Association (NPFA)[71] as well as the Government[72] recognise the importance of and try to promote the use of local standards. One among several witnesses with a similar view warned that:

"The risk with national standards is that they become a straight jacket, stifling innovation, thought... when drawn up locally they are best placed to actually fit properly in the circumstances, needs and opportunities of that community".[73]

Very few councils have derived their own local provision standards. Most have simply adopted standards used elsewhere, sometimes without understanding their derivation or limitations for their own particular context. In large part this is driven by two things: a lack of both resources and an agreed methodology for deriving local standards.

  26. Witnesses pointed out the main difficulties in deriving local standards:

"There is also an issue about the cost effectiveness of requiring local authorities to go to that level of detail, to keep re-inventing the wheel and producing their own standards which have to stand up at public inquiries";[74]

and

"resources are not put in to ensure that assessment of need/determination of standards take place".[75]

27. In the absence of local specifications,[76] local authorities have commonly drawn on national standards, such as the NPFA 6-Acre Standard. It is used for two main reasons: it is defensible in the planning system, and does not incur the costs involved in setting local standards. The NPFA Standard dates back to 1938. It advises that there should be provision of 6 acres of public open space for every 1000 people. One local authority, when questioned by the Committee, agreed that:

"the NPFA does in fact provide a comfort blanket".[77]

Local authorities adopt the standard because their planners think that NPFA:

"gives them a defensible standard at inquiries. If you go out on your own, making your own judgements, that is more open to challenge".[78]

Such challenges are a significant concern for local authorities.[79]

28. However, blanket use of the NPFA standard has also been a serious problem. It has been criticised for encouraging local authorities to be quantitative in their standard setting. NPFA have accepted this criticism and stated in oral evidence that:

"There may be a tendency to look superficially at the quantitative issues that we are talking about and not recognise the importance of quality of facilities locally for people".[80]

It added:

"We would not wish people to think that the NPFA Standard should be slavishly adhered to; but we do think that it is a good working tool and, until something better comes on to the table, I think it should be retained. We would also say that local studies are very important for putting local reflection on the position".[81]

29. Some witnesses stressed the need to ensure that standards are set not only in relation to quantity, but also quality[82] and accessibility.[83] Helen Woolley told the Committee:

"I think there are three levels of accessibility. The first is, is there an open space or a park close to where I live - because that is what most people want - or is it obstructed by a road or canal or something? Can I get to it? It is alright it being there, but can I get to it? Is my wheelchair going to tumble over on the way there because of the camber of the footpath or, if I am going in the car, is there somewhere I can park my car and safely get out and it is not a gravel surface so that I cannot get my wheelchair out and play with my kids. When I get there what is it like within the space?".[84]

30. For far too long local authorities have based their approach to standards of open space provision primarily on the quantity of provision, supplemented in many instances by the physical distance from households, with little or no regard for quality. We are strongly of the view that quality - and especially the declining quality of much existing open space - is of fundamental importance and something the planning system must address. Quality means not just attractiveness but fitness for purpose - useability. Broadly speaking, provision standards should include at least quantity, quality and accessibility, but the relative priority which the planning system should give to each of them will vary from one context to another. Identifying these priorities at the local level will require planners and those responsible for long term management to consult users and their local communities. It follows that different priorities may exist in different parts of a single local authority area and therefore before "broad-brush" quantitative methodologies, such as the NPFA, LPAC or English Nature models, can be used, they must be modified on the basis of local information. This information can come from local landscape surveys and open space audits which address not just quantity but also a range of accessibility and quality issues (eg landscape value, amenity, providing shelter, bio-diversity and condition), coupled with information from household and user surveys. A much better approach, however, will be for local authorities to develop their own local standards from first principles. However, since many local authorities are uncertain what they should actually do, they could be positively influenced by more detailed, and even prescriptive, guidance. We endorse strongly the requirement in the draft revision of PPG 17 that planning authorities should draw up comprehensive and locally-determined standards of provision. Related to this, we also recommend that, in the final version, the Government make absolutely clear that it does not endorse the continued use of national standards. We regard the comment to this effect in DTLR's Memorandum to our inquiry as admirably clear and recommend that it should be included in the PPG.

31. A possible means of encouraging more strategic planning would be to encourage or require the preparation of open space strategies. The Garden History Society argued that:

"The PPG should be the ideal vehicle for government to express its strong advice that every local planning authority should produce 'parks and open spaces strategy'. Such a strategy needs to be based on a consistent typology, good data and needs-assessment".[85]

The Greater London Authority will make the preparation of open space strategies for London boroughs a requirement in the forthcoming London Plan, and talked about the benefits of open space strategies when it gave oral evidence to the Committee.[86] The Heritage Lottery Fund, which has awarded substantial sums of money to projects for historic parks, highlighted the benefit of:

"requiring the strategies and producing, hopefully, some guidelines to back up that requirement; that will mean local authorities go out and do that work, do assess the needs within their area and do have a much better understanding of what they currently manage now and what they should be managing in the future".[87]

There are problems associated with requiring open-space strategies, mainly to do with lack of resources to create, and more importantly, implement strategies. There are already requirements for a wide range of strategies. We were informed that:

"We do not want a free standing strategy that is just put on the shelf - it needs to be embedded in a whole range of thinking about local areas".[88]

Despite these problems[89] we were told that the benefits were so well established that strategies should be a requirement:

"The publication of the PPG is an ideal opportunity to make the preparation and implementation of such a strategy [greenspaces strategy] a requirement for all local authorities ... it should inform other, area-based, supplementary planning guidance and be considered as a material consideration under section 54(a) of the Planning Act".[90]

The Government's recent Planning Green Paper indicates that it sees the planning system as a mechanism for the delivery of the land use elements of local strategies[91]. This idea could also help bring planning and management together.

32. Whether the proposed process guidance is in a supplementary document or in the PPG itself, the Government should set out its planning framework more clearly. A reasonably common view was that the Government should include a clear statement of what it wants the planning framework to be, within this PPG, starting with an assessment of need. Clear definitions and a hierarchy of space and facilities will be important in ensuring that local authorities are able to assess the value of existing facilities and establish the community's need. There should be a requirement for such needs assessment to include community involvement. The needs assessment should lead on to, and feed into, the setting of local standards of provision. Local authorities could then create open space strategies that would ideally attempt to link planning and management together and could be co-ordinated with other strategies and linked to Best Value performance plans. These open space strategies could then feed directly into development plans as suggested in the Planning Green Paper.[92] A diagram of the planning framework as outlined here can be seen at Annex 3 to this Report.

33. The Committee has heard overwhelming evidence for, and is convinced of, the need for a clearer framework for planning for open space. The Government has accepted that PPG 17 lacks clarity.[93] Comments from the Department also suggest that the intention of the guidance is to provide such a framework along the lines of the following:

"look at actually what your community's needs are, assess actually what you require to meet those needs, and through a sensibly put together strategy in your development plan, look to deliver on those."[94]

The Committee recommends that the PPG be redrafted to create a better framework for planning by providing:

    (a)  better guidance on the assessment of need with a greater emphasis on accessibility;

    (b)  a clearly defined typology of open spaces (hard landscapes - squares, roads, parks; green spaces; and recreational facilities - formal sports facilities and informal areas, including those for children's play), together with guidance on how to create a locally agreed hierarchy of open spaces;

    (c)  specification of what design criteria should be applied when planning new developments, or enhancing existing ones.

and by requiring local authorities to:

    (d)  create locally agreed standards for open space that include standards of accessibility linked to the needs of different age and social groups;

    (e)  create open space strategies, following a needs assessment and setting of local standards; these strategies would relate need to existing provision, taking account of the available resources; and should, in turn, inform development plans;

    (f)  include locally agreed standards and open space strategies in development plans.

Greater guidance on some of the points mentioned above could be given in a companion document. Therefore the Committee recommends:

    (g)  the publication of a companion document to provide more detailed process guidance.

INADEQUATE PROTECTION OF EXISTING OPEN SPACE

34. The Urban White Paper states that the revised PPG 17 will "aim to ensure that existing spaces are protected from development ...". but some witnesses argued that the draft PPG fails to meet this objective.[95] One reason for this is the draft's failure to give enough emphasis to quality. As one witness told us

"The loss of greenspace to other development is frequently preceded by a deterioration in its quality...".[96]

Open space in a bad state, which is not considered to be of value to the community, can soon be seen as only too suitable for development.[97]

35. The PPG's guidance on land exchange was also a cause for concern. While allowing land exchange to take place "to compensate for loss of recreational provision at another location the PPG states that the land exchanged should be both "equivalent" to that lost, and local authorities "should aim to realise a qualitative gain for the community".[98] It was feared that, in effect, developers were being given carte blanche to redevelop potentially valuable playing fields for more profitable uses, provided they replaced them elsewhere. Ultimately, this could lead to all playing fields being located on the urban fringe or in the green belt as they will clearly meet the criterion of being: "sites where other forms of development are precluded".[99] One witness set out the problem:

"With land exchange schemes there might be a temptation, as we have already seen in parts of inner London, to use valuable open space for development and exchange it for a rather less valuable playing field on the outskirts of the city, which is not part of the urban renaissance".[100]

36. Several witnesses argued that the 1991 guidance offered better protection for open spaces than the revised draft. Sport England highlighted the criteria based approach to determining whether playing fields could be developed which was contained in the earlier PPG. In the place of this criteria based approach, the new PPG allows development of open space simply where land is not valued or is surplus to requirements. The Countryside Agency warned that this means that:

"unless local planning authorities have conducted detailed assessments which declare particular open spaces to be of value they can be declared 'surplus to requirements' and be regarded as suitable for development".[101]

The organisation argued that: "the burden of proof should be the precise opposite"; there should be no development of open space unless it is proven to be of no value to the community.[102] The Development Control Process flow chart included in memorandum PPG 05 gives an example of a development control process which could be followed to ensure open space is adequately protected.[103]

37. There has been an increase in the loss of public space through sales of playing fields. In 2001 there was a 60 percent increase in the sale of playing fields with 679 applications to develop on playing fields being approved, compared with 439 in the previous year.[104] The Government document A Sporting Future for All (2001) promised that figures on playing fields disposal would be published monthly by a monitoring unit from the Department for Culture, Media and Sport (DCMS), the Department of the Environment, Transport and the Regions (DETR - as it was then) and the Department for Education and Employment (DfEE - as it was then). Since the first meeting of this group well over a year ago, no figures have been published.[105] DCMS has accepted that there is a need to publish such figures as soon as possible and have promised that this will happen in January and February 2002.[106]

38. Some witnesses expressed their concern that the existing guidance will allow small pitches to be sold off too easily. Sport England is currently a statutory consultee in applications to sell off pitches of 0.4 hectares or more, but many pitches, especially those used for children's sports are smaller than that. Accordingly Sport England has claimed that the size of pitch on which it should be consulted be changed from 0.4 to 0.2. Sport England has indicated their willingness to take on responsibility for these smaller pitches[107] and the Central Council for Physical Recreation has supported this proposal.[108]

39. In some cases it may be that the sale of open space is acceptable, particularly if that space is in an extremely poor state and has little chance of being enhanced. Some spaces are in such a poor state that they might be described as a 'green deserts', and, in fact, reduce the quality of their environment. In some cases, where a whole area is being regenerated, the most beneficial option may be to re-plan the distribution of open space. However, in many urban areas the pressure on open space is great and will increase with growing urban development. This means that re-locating open space in such places could have the effect of reducing the amount of space which is in close proximity to urban homes. This PPG should address the increasing density of population in urban areas, but sadly fails adequately to reflect the trends toward urban living and the subsequently increasing need to protect open space. The current draft provides inadequate protection for open space. We recommend that the PPG be redrafted to give better protection to existing open space by:

    (a)  giving more emphasis to the need to prevent deterioration of quality of existing open space;

    (b)  revising and clarifying the policy of land exchange; and

    (c)  requiring planning authorities to consult Sport England when there are proposals which would affect playing fields of 0.2 hectares or more.

The Committee also recommends that:

    (d)   the reporting mechanism for publishing monthly information on playing pitch disposal be implemented immediately.

40. In its report on Travelling Fairs in 2000 the Environment, Transport and Regional Affairs Committee recommended:

"no large community ought to be without a central focus for public entertainment, a base where events such as funfairs can be held. Villages, towns and cities with such spaces ought to ensure that they are designed to make holding funfairs easy, with good access to services such as water and electricity while those that do not have such areas ought to be striving to get them as recommended in the current Planning Policy Guidance Note 17 (PPG 17). Further we recommend that the revised PPG 17 makes specific reference to the value of historic travelling fairs and the role which they can play in the regeneration of town centres".

In its Response, the Government agreed with the Committee and indicated that it would be setting out proposals:

"to help local authorities secure stronger protection of valuable open space in a draft revision of planning policy guidance note 17... which will be issued for public consultation soon. This will help to ensure that the sites which can be used by fairs are available in the future".

We are disappointed that the draft PPG 17 does not adequately meet the recommendations the Environment, Transport and Regional Affairs Committee made, which the Government agreed to, to retain historic sites for fairs and encourage the creation of new sites in places where they do not exist.

41. In the same report we drew attention to the difficulty travelling showpeople faced in finding sites for their winter quarters. While our predecessor Committee fully concurred with the principle of protecting the green belt from suburbanisation and inappropriate development, it did argue that showpeople's depots were rather different in nature from housing development. The Committee suggested that there were a number of brownfield sites in the country which may lie in officially designated green belt land but could be developed for travelling showpeople's accommodation without significantly altering the character of the green belt. A similar situation arises in respect of stables. We received a submission from the Epsom Trainers' Association pointing out that numerous yards that had been near or in Epsom were developed "due to urbanisation" prior to 1970 and that in the last 30 years there had been a dramatic decline in the number of horses in training and available stables to train from in the area. We were told Epsom had an urgent need to develop a small number of sites to provide the space for the industry to "regain critical mass". These, we were told, should be strictly limited in numbers so as to provide protection for the green belt, but because of the nature of the industry they are likely to have to be built in green belt areas". The Epsom Trainers' Association argued that PPG 17 should permit limited development to support facilities for major sporting centres providing that the development would be part of an agreed strategy drawn up in partnership with planning authorities and would have to be restricted by covenant or other legal means for the original designated use. While we deprecate in general the suburbanisation of the urban fringe, in particular by the movement of sports' fields and other facilities from inner urban areas to the green belt, we do understand that there are certain activities which need to take place on the urban fringe. Accordingly, we recommend that in redrafting the PPG the Government take account of the need to provide for such activities, in particular winter quarters for travelling fairs and the provision of stables.

RESOURCES AND FUNDING

42. The 'Partial Regulatory Impact Assessment for Revision of Planning Policy Guidance Note 17 (PPG 17)' which accompanied that publication of the revised draft, stated that the revised guidance "should not impose further costs" . We were told that this is unlikely. Moreover, if it does not impose further costs, the PPG will have failed because nothing will have changed. Local authorities do not have the funds available, nor do they have the skilled staff, to carry out what is currently required of them and so often fail to meet requirements. They will continue to fail unless resource implications are considered and addressed. With the best guidance in the world the desired strategic planning and implementation will not happen without the supporting resources.[109] Nor will community involvement be effective and sustainable. As one witness pointed out:

"there may be a friends group which is more like an enemies group, so to speak, in respect of some local authorities".[110]

Budgets are increasingly squeezed but space and facilities often lose out to fundamental services such as social services and education.[111] The message is clear that if we want high quality open space we are going to have to pay for it.

43. Some think that spending money on open space could reduce the need for spending in other areas such as education. The Urban Parks Forum argued that:

"If you put money into open space, existing or new, it can decrease your costs elsewhere..."[112]

Ken Worpole of the Urban Green Spaces Task Force argued that it was easy to see how putting increased money into sports could reduce health and possibly even crime-related costs but noted that the same approach is not taken to open space. As a result open space is underfunded:

"The way you fund it is the same way as if you decide that you really want Britain to become a world­class sporting nation - you put money into it. If you want people to live in towns and cities and live healthily, you have to put money in. That has to come from local authorities or central government or a combination of the two. You either take open space as seriously as you take indoor space or you just let it go to the dogs."[113]

44. One source of funding is section 106 agreements, made between local authorities and developers under section 106 of the Town and Country Planning Act 1947. These are commonly used to require developers to contribute money to the provision of new open spaces. Although the use of section 106 funds in this way can be of great benefit, it was pointed out that there is little sense in planning authorities requiring developers to provide or contribute to new open spaces if existing ones in the area are run-down and unattractive. Developers can contribute to the enhancement of existing facilities and hence help to regenerate a whole area. This will be increasingly important as the pressure to build new housing in urban areas will put greater pressure on nearby recreation facilities and parks and open spaces. Furthermore, in some areas, improving the quality of existing open spaces may well be the best use of any money from planning gain, or whatever its equivalent is in future. Nevertheless, the use of section 106 agreements to enhance existing space and facilities is not without problems since the areas with many new developments will benefit most from section 106 agreements for off-site provision. This runs the risk of further neglect of already deprived areas where no new development is taking place. Funds provided through planning obligations and agreements should make a useful contribution to enhancing and maintaining existing open spaces, but they do not dispense with the need for local authority expenditure.

45. While developers can be asked to make payments for the enhancement of existing spaces, the situation in respect of paying commuted sums for their maintenance is more difficult and complex. First, developers may be reluctant to pay commuted maintenance sums. In written evidence The House Builders Federation expressed strong opposition in principle. However, when questioned by the Committee it became clear that witnesses were concerned about increases in the amount of money they would be asked to pay, rather than what the money was spent on.[114]

Secondly, there is currently some ambiguity about whether or not developers can be asked to pay commuted sums to provide for future maintenance. Paragraph 62 of PPG 17 suggests that contributions to the maintenance of off-site open space is justified, but most councils took the view that DoE Circular 1/97 prohibited this. If so, the PPG's recommendations for use of section 106 funds for maintenance conflict with DOE circular 1/97 except when the off-site provision will be principally of benefit to the development itself rather than the wider public. The daughter document of the Planning Green Paper on planning obligations proposes changes which will allow much greater flexibility for councils seeking funds for maintenance.[115]

46. Spending on space and facilities is also supplemented by lottery funding. The Heritage Lottery Fund was widely praised by many witnesses; on the other hand the New Opportunities Fund (NOF) was widely criticised. There has been concern about the reduction in spending on open space and the large delays that have occurred between allocation and spending of funds. The New Opportunities Fund allocated £125m for a Green Spaces and Sustainable Communities programme in 1998. Only £3.8m has been actually been spent so far and the details of this are given in the table below. The reason for this fiasco, we were told was the long process of distributing money to Award Partners who allocate the money to actual projects.

New Opportunities Fund Green Spaces and Sustainable

Communities Awards before October 2001[116]

Scheme

Awards

Barnardo's

Better Play


First grant panel 29 October 2001. Agreed year one allocation: (at least)

£2.3 million


BTCV

People's Places


10 awards made to date, representing:

£79,623


Countryside Agency

Doorstep Greens


Proposals for project development grants under consideration.

English Nature

Wildspace!


44 awards made so far, representing:

£2,01,832


RSNC

SEED


29 awards made so far, representing:

£655,882


Sport England

Playing fields and community green spaces


11 applications for school play grounds strategies and 9 playing fields strategies approved, representing:

£291,752


Sustrans

Green routes, safe routes


It has been agreed that the total funding committed to Sutrans will support the following projects: 14 green routes, 30 Safe Routes to Stations, 12 Home Zone projects and Safe Routes to Schools (60 bike sheds and 50 walking buses).

Scottish National Heritage and Forward Scotland

Fresh Futures


First panel awarded 7 grants: representing:

£143,951


Highlands and Islands Enterprise

Scottish Land Fund


22 awards made so far, representing: £662,754

Enfys Scheme

Enfys Consortium,


First panel meeting planned for 30 October.

Creating Common Ground Consortium

(GCGC)


First panel meeting planned for 14th November.

47. In its new programme, Transforming Communities NOF has reduced planned spending on open space. Of the £159m provided for this programme, £10m is earmarked for "community drugs rehabilitation", £50m for development of sources of renewable electricity generation; and of the remaining £99m half is to be spent on "community waste projects". This leaves less than £50m over three years for anything like green space. Even this relatively small amount is to cover not just green space, but all open space, cycle routes, community buildings and local heritage projects. One witness commented:

"let's hope the NOF money will filter through to those projects, but we still have to face the question of how do we fund our mainstream portfolio of parks and civic squares, and that has to come through mainstream spending."[117]

48. In view of the difficulties faced, many witnesses argued for an open spaces agency to lobby for open space, to raise funds for its enhancement and improvement and to advise on it. Our predecessor Committee had made a similar recommendation (for a Parks Agency) in its report into Town and Country Parks. Alan Barber of The Institute for Leisure and Amenity management (ILAM) told us:

"The problem that we do not have a national agency.....Sport England is mentioned 17   times...[in the PPG]".[118]

He and others argued that such an agency could usefully provide guidance on the production of open space strategies[119] and went on to tell the Committee:

"I am quite sure that the decline that has taken place in green spaces that are managed by local authorities would not have been anything like as severe if the equivalent of a Sport England or a Countryside Agency had been at work".[120]

Ken Worpole pointed out that Sport England:

"is a professional organisation with professional researchers able to rally lots of evidence in support of its case. We do not have the same kind of capacity for the environmental case or the social case. There is not only a Sports Lottery Fund but sport seems to be getting a substantial part of the New Opportunities Fund as well, so they are getting two bites of the cherry. So it is a powerful lobby ".[121]

The Urban Parks Forum , which is largely funded by DTLR, is the closest organisation to a national agency but it does not consider itself able to adequately fulfil the role:

"We are trying to be that but we have not got the financial resources of Sport England".[122]

49. We were appalled that the New Opportunities Fund is reducing spending on open spaces before previously allocated money has been spent and its impact measured. The Committee is persuaded by the evidence from witnesses that one of the major problems afflicting space and facilities is lack of adequate revenue funding. We support the use of section 106 funds both to enhance and to maintain existing spaces. We also agree with the Government that local authorities should spend more on the management of open space and facilities but this must be facilitated by central Government. We conclude that the creation of a well-funded open spaces agency would be beneficial in assisting greater collaboration between planners and managers and, with the help of an articulate chairman, could secure higher levels of funding for open space. The Committee was impressed with, and recognises the important role played by Sport England's Chair, Trevor Brooking, in drawing attention to and raising the profile of sport. The Committee recommends that:

    (a)  local authorities be given sufficient funds to allow them to spend more on, and have the staff to see to, the management of open spaces in their care; without this nothing will change;

    (b)  as part of the reform of the planning system, the Government permit funds arising from planning obligations to be used for the enhancement, management and maintenance of off-site facilities and open space; whatever takes the place of section 106 agreements should be used in ways which are transparent and consistent to give greater clarity to developers;

    (c)  the New Opportunities Fund increase spending on open space (in line with the Urban White Paper) rather than cutting spending as the Transforming Communities Initiative proposes; and

    (d)  the Urban Green Spaces Task Force consider the desirability and feasibility of establishing an advocate and champion for urban open space spaces, which will need significant resources and a status comparable to that of a Non-Departmental Public Body.


25   Revised Planning Policy Guidance Note 17, 2001, para 5 Back

26   For example see PPG05 Back

27   PPG18 Back

28   For example, Sport England, Institute for Leisure and Amenity Management, The British Gliding Association (PPG02). See also Q 291. British Water Ski have also made this comment in respect of motor, air and water sports which can be very contentious and British Water Ski have had problems and disagreements with English Nature concerning the implications of the Countryside and Rights of Way Act (for details see PPG09) Back

29   QQ 69, 444 Back

30   Q 427 Back

31   The Inland Waterways Association (PPG01), The Association of Inland Navigation Authorities (PPG15), British Waterways (PPG16) and Inland Waterways Amenity Advisory Council (PPG20). The Institute of Amenity Management (ILAM) pointed out in their Memorandum: "Many of the best used and most valuable recreational landscapes are those which combine high quality greenspace and water space" (PPG07, pp 5.) ILAM lamented the lack of guidance as did the Environment Agency who notes that the revised PPG should "recognise more fully the role of water and waterside land in providing open space and places for sport and recreation in urban and rural areas" (PPG21) Back

32   PPG13 Back

33   PPG19 para 3 Back

34   Revised PPG17, para 15 Back

35   Q 347 Back

36   Revised PPG17, para 6 Back

37   Eleventh Report, 2000­01 Walking in Towns and Cities (HC 167­I) Back

38   The Civic Trust, response to DTLR consultation, DTLR377 Back

39   PPG10 para 3 Back

40   Q 44 Back

41   PPG08, para 8.1 Back

42   PPG14, para 3.5 Back

43   Q 401 Back

44   Planning Policy Guidance Note 3 Back

45   Q 207 Back

46   PPG07(a) Back

47   PPG05 Back

48   Q 348 Back

49   Revised PPG17, para 2 Back

50   Q 357 Back

51   Q 341 Back

52   The Town and Country Parks Report provides much anecdotal evidence of this, and it was confirmed by the Urban Parks Assessment 2001.  Back

53   Q 208 Back

54   Q 401 Back

55   QQ 90-2 Back

56   Q 430 Back

57   Q 389 Back

58   Revised Planning Policy Guidance Note17, para 2 Back

59   Q 3 Back

60   PPG26 Back

61   Q 291 Back

62   Q 394 Back

63   Planning: delivering a fundamental change, DTLR December 2001 Back

64   PPG05 Back

65   PPG 26 Back

66   See PPG03 Back

67   Q 196 Back

68   PPG05 Back

69   PPG23 Back

70   PPG17, para 5.6 Back

71   "We would again turn to the fact that local assessments need to be undertaken" Don Earley, NPFA, Q 283 Back

72   The DTLR memorandum to the Committee notes (in paragraph 5.6) that "The Government has considered whether national standards should be included in the new PPG17, but firmly believes that local assessments are a better approach to planning for sport, open space and recreation than one which sets minimum standards of provision to be applied across the whole country. The Government does not believe that national standards can cater for the wide variety of situations found in individual local authorities." Back

73   Q 99 Back

74   Q 137 Back

75   Q 276 Back

76   QQ 127-129 Back

77   QQ 129-131 Back

78   Q 125 Back

79   Q 126 Back

80   Q 290 Back

81   Q 278 Back

82   QQ 434, 435 Back

83   Q 382 Back

84   Q 382 Back

85   PPG03, para 13 Back

86   Q 188 Back

87   Q 305 Back

88   Q 14 Back

89   Evidence from the Public Parks Assessment (DTLR 2001) shows that parks and open space benefit from the existence of dedicated parks and open space strategies. At present only 15 percent of authorities have such a plan, with 20 percent intending to have prepared one within the next 12 months. There is a clear correlation between the existence of a strategy and higher rates of parks in good and fair condition. On the contrary, there is little evidence of Cultural Strategies at regional or even local level tackling parks and open spaces in the kind of detail required to be effective - they remain heavily biassed towards arts, museums, the creative industries and to some extent, sport. (Cultural Strategies, which are promoted and required by Department of Culture Media and Sport, are produced by Local Authorities and can be regional or district wide.) Back

90   PPG07(a) Back

91   December 2001,Planning: delivering a fundamental change Back

92   December 2001,Planning: delivering a fundamental change Back

93   QQ 69, 68 Back

94   Q 99. Back

95   Our towns and cities: the future - Delivering an urban renaissance, November 2000, Cm 4911 Back

96   PPG07(a) Back

97   PPG07(a) Back

98   Revised Planning Policy Guidance Note 17, paras 35, 36 Back

99   Revised Planning Policy Guidance Note 17, para 36 Back

100   Q 351 Back

101   PPG19, para 3 Back

102   PPG19, para 3 Back

103   This chart is likely to be included in the forthcoming Scottish Planning Advice Note on Open Space Back

104   Sunday Telegraph 18/11/01: Playing fields sell-off up by 60 per cent Back

105   Q 552 Back

106   Q 555-9 Back

107   Q 62 Back

108   PPG14(a) Back

109   "We have not done an assessment absolutely in terms of assessing each part of green space because of the resource implications involved" Q 132 Back

110   Q 308 Back

111   Urban Parks Forum 2001 Public Parks Assessment Back

112   Q 371 Back

113   Q 358 Back

114   QQ 244-259 Back

115   The Committee will hold an inquiry into the Government's proposals for the future of planning set out in the Green Paper. See Press Notice 38/2001-02 for details Back

116   The table issued by the New Opportunities Fund reflects total funding committed to projects under the green spaces and sustainable communities initiative at the time of the Select Committee PPG 17 inquiry. It represents decisions taken from launch of green spaces and sustainable communities schemes in summer 2001 until the hearing in October 2001. Back

117   Q 360 Back

118   Q 200 Back

119   Q 201 Back

120   Q 204 Back

121   Q 353 Back

122   Q 381 Back


 
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