Memorandum by English Heritage (PPG 06)
1. English Heritage welcomes the opportunity
to submit a memorandum to the Sub-Committee on planning for sport,
open space and recreation. Because of our statutory remit, our
comments are necessarily restricted to England.
2. English Heritage is the Government's
lead body for the historic environment in England. Its tasks include:
advising national and local government
on all aspects of the historic environment;
advancing understanding of the historic
environment through survey and research;
giving £38 million a year in
grants to historic buildings, sites, parks and gardens;
managing 409 historic properties
(including parks and gardens) on behalf of the state;
running the National Monuments Record;
through our educational work, increasing
public understanding of the historic environment.
3. English Heritage submitted comments on
the public consultation draft version of PPG 17, and together
with the Countryside Agency, English Nature and Sport England
raised common concerns in a joint letter to Lord Falconer.
4. PPG 17 was originally published in 1991,
and revised guidance is long overdue. In its comments, English
Heritage therefore welcomed the decision to update it, but felt
that the draft was premature, as the Ministerial Urban Green Spaces
Task Force had not yet completed its work. We were looking to
a revised PPG to be one of the keys to the urban renaissance promoted
by the Urban White Paper.
One of our main concerns was the lack of recognition of the historic
and cultural importance of parks and other open spaces, and of
their critical role in neighbourhood renewal and in the creation
of "liveable" cities.
5. Although responsible for very different
sectors, the four agencies all felt that the draft represented
a missed opportunity.
6. Squares, walks, commons and open spaces
used for many different kinds of recreation were a feature of
England's pre-industrial towns and cities, but were rarely provided
in the rapidly growing urban centres of the late eighteenth and
early nineteenth centuries. In 1833, the report of Select Committee
on Public Walks recognised the need to provide public walks and
open spaces for "comfort, health and content", which
helped to spur the municipal park movement during the middle years
of the nineteenth century.
The same concerns are still relevant, and public open space remains
critical to the quality of life in urban areas.
7. The English townscape is characterised
by the number and diversity of its public open spaces. Not all
are owned and managed by local authorities, and the planning system
has an important role to play in ensuring their survival and protecting
and enhancing their character and value. Other incidental open
spaces, including private gardens, also play an important role
by providing "green lungs" and creating a sense of place.
8. As long ago as 1902, an Act was passed
to protect the landscape and views from Richmond Hill in London
for the benefit of the public. Currently, the Register of Parks
and Gardens of Special Historic Interest in England
includes over 1,400 sites, including nationally important examples
public and country parks, squares, cemeteries and allotments.
It is nevertheless important to remember that open spaces often
have historic character and value even if they are not formally
designated as conservation areas or registered landscapes. There
is no part of England that human beings have not helped to shape
and transform, and the environment as a whole has a historical
dimension that needs to be recognised, understood and evaluated.
9. England's public parks used to be symbols
of civic pride. Their success, and the quality of their design,
is demonstrated by the extent to which that they are still valued
by their users, even where they are no longer adequately maintained.
10. A joint report published in 1993 by
the Garden History Society and the Victorian Society
highlighted the need for action to rescue public parks from decline.
The quality of what is at risk is demonstrated by English Heritage's
annual Buildings at Risk Register, which shows that 34
Grade I and II* listed structures are currently at risk in registered
local authority parks. Since Grade I and II* listing and registration
are both of necessity highly selective, this is a worryingly high
figure, the tip of an iceberg. Following the former Environment
Select Committee's recommendations on Town and Country Parks,
English Heritage joined DTLR, the Heritage Lottery Fund and the
Countryside Agency to commission a survey of local authority owned
parks to quantify the problem. The report
shows that the loss of features and facilities traditionally associated
with historic parks like fountains, cafés and toilets is
widespread, and that this decline looks set to continue. Sport
and recreation facilities such as boating, paddling pools, tennis
courts, golf and putting are also disappearing. In all, 39 per
cent of parks and open spaces are in decline.
11. District-wide sport and recreation strategies
were recommended in the 1991 PPG, but, 10 years later, the condition
of public parks and open spaces suggests that the aspiration to
bring together land-use planning and other local authority strategies
has not yet been achieved. English Heritage's recent guidance
on streetscape design, Streets for All ,
highlighted how poor management can undermine character, and argued
the need for integrated townscape management. A comprehensive
vision is essential, and the new version of the PPG needs to help
local authorities achieve this at neighbourhood level.
12. We would not advocate free-standing
strategic plans for open space, since local authorities are already
suffering from strategic overload, but strategic thinking about
open space should be an integral part of Local Cultural Strategies
and Community Strategies and in planning for neighbourhood renewal.
13. The Urban Green Spaces Task Force is
developing definitions of different types of green space and their
related community values. The PPG could usefully be complemented
by good practice guides embodying quality standards (tying in
benchmarking and Green Flag awards) for the whole range of public
open space, including, where appropriate, horticulture. This would
mirror other design guides linked to PPGs, such as DETR's By
and PPG 13 Transport: a guide to better practice.
14. Sustainable high-quality open space
requires effective management and maintenance as well as good,
sensitive, design, responsive to the needs and character of the
area. It is therefore important that any design guidelines or
good practice guides linked to the PPG emphasise the importance
of taking future maintenance costs into account.
15. This does not necessarily mean abandoning
traditional horticulture. For example, Haringey Borough Council
used carpet bedding to publicise the 1997 European Year Against
Racism, with photographs of the planting being used in a wider
publicity campaign, while the popularity of gardens like those
of Hampton Court suggests that expenditure on horticulture can
be fully justified in terms of its contribution to the quality
of life. Quality open space is most needed in poor high-density
neighbourhoods, where local authorities need more support.
16. Public open space is precious and needs
to be protected. The draft PPG seeks greater protection for playing
fields, and a general presumption against development should now
be firmly established. However, without thoroughly understanding
the role and function of a particular open space (which may well
evolve and shift over time) it will not be possible to say whether
it could be released for development, or to determine the type,
size or location of any new sites that might be required in mitigation.
Not all open space is substitutable: there is an acute shortage
of open space in some neighbourhoods, and some sites, including
many historic public parks, will be irreplaceable.
17. A presumption against development should
also ensure that sites are not at risk of being eroded, for example
by road improvements. Public parks in particular are often surrounded
by land of prime development value, which can make them an easy
option when new public facilities are required. The PPG needs
to provide clear guidance on new buildings and structures on these
sites to guard against inappropriate or unrelated development.
New development in or adjacent to open space needs to take into
account its character and potential if it is not to diminish its
value. The historical dimension needs to be considered and its
significance identified and evaluated whether or not the land
is formally designated as a conservation area or registered landscape.
18. The PPG could helpfully consider potential
conflicts between various protective policies such as sports provision
and open land. For example, open-air sport has been regarded as
an appropriate use of Green Belt land despite the fact that sophisticated
modern facilities may no longer be in the spirit of retaining
expansive open and green landscapes.
19. The PPG could consider how public open
space might benefit more through the use of planning obligations.
Local plan policies need to identify how s 106 agreements might
be used, not only to provide new green spaces but to improve the
management and maintenance of those that already exist. Local
authority urban designers need to advise more generally on the
provision and design of open spaces in planning applications.
20. Dame Jennifer Jenkins summed up the
role of public open space in urban renaissance in her comments
published on 23 August 2001: "British cities are beginning
to realise that their reputations are mirrored in their parks,
a lesson most strikingly demonstrated in New York, where the descent
of Central Park into a no-go area was a sign of the city's decline,
while its restoration signalled the city's revival . . . until
neglected spaces in run-down neighbourhoods match well cared-for
gardens in prosperous city centres, regeneration will be an empty
21. The results from the MORI poll commissioned
last year for Power of Place
(the report to Government led by English Heritage on the future
of the historic environment) showed that:
88 per cent of the population thinks
that the historic environment is important in creating jobs and
boosting the economy;
87 per cent think that it plays an
important part in the cultural life of the country;
87 per cent thinks it is right that
there should be public funding to preserve it;
85 per cent thinks it is important
in promoting regeneration in towns and cities.
22. Quality urban green space brings a cascade
of economic, social and environmental benefits such as land values,
people's health and well being, pleasant routes for pedestrians
and biodiversity. The PPG needs to provide useful, focussed guidance
on how these benefits can be identified, evaluated and delivered.
23. Public parks can be stimulating and
safe environments for children to play, but they need to be well
managed and maintained. Given the quality of much traditional
park design, it will often be sufficient to provide adequate staffing
for security purposes and to reinstate traditional features and
essential facilities such as toilets rather than provide new infrastructure.
The Public Parks Assessment report highlights the loss
of children's play features like paddling pools. Successful park
management for children would have the effect of creating attractive
parks for everyone to enjoy.
24. The Urban Green Spaces Task Force's
research on the numbers and types of users, patterns of use, groups
of users, and non-users and barriers to use will provide useful
information for the PPG.
25. The key points from this memorandum
Liveable cities depend on quality
public open space, and good sport and recreation provision.
The planning system has an important
role in guiding the provision and management of public open space,
but is only one mechanism among many.
A PPG on public open space is welcome,
but needs to be fully developed (it would be better titled "public
open space, sport and recreation", to distinguish between
the land resource and its uses).
Like the Urban Green Spaces Task
Force, the PPG needs to take an integrated approach to open space.
Open space can serve a wide range of different functions and have
multiple values and significance. They all need to be taken into
Open space is an important part of
the historic environment. Understanding and evaluating its significance
26. We have no objection to this memorandum
being made available for public inspection.
3 DETR (2000): Our Towns and Cities: the Future. Back
See Hazel Conway (1991): People's Parks. Back
English Heritage (1998): The Register of Parks and Gardens:
an Introduction. Back
Garden History Society and the Victorian Society (1993): Public
Prospects: Historic Urban Parks under Threat. Back
House of Commons Environment, Transport and Regional Affairs
Select Committee (October 1999) Twentieth Report: Town and
Country Parks. Back
DTLR, Heritage Lottery Fund, English Heritage and the Countryside
Agency (May 2001): Public Park Assessment. Back
English Heritage (2000): Streets for All: a London Streetscape
DETR (2000): By Design: Urban Design in the Planning System. Back
English Heritage (2000): Power of Place. Back
See Mike Luther and Dietwald Gruehn (2001): "Putting a Price
on Urban Green Spaces" (Landscape Design September
House of Commons Environment, Transport and Regional Affairs
Select Committee (June 2001) Eleventh Report: Walking in Towns
and Cities. Back