Select Committee on Transport, Local Government and the Regions Memoranda


Memorandum by Council for the Protection of Rural England (CPRE) (PPG 10)

INTRODUCTION

  1.  CPRE welcomes the opportunity to submit evidence to the Urban Affairs Sub-committee on draft PPG 17 Sport, Open Space and Recreation. Our involvement in such planning policy stems from our interest in encouraging the sustainable use of land and other natural resources in both town and country to ensure change values its natural and built environment. We believe it is essential that PPG 17 incorporates a better understanding of the role of recreation, sport and open space in shaping our quality of life and its wider implications for and in the countryside.

  2.  The draft PPG 17 represents a welcome advance in national planning policy provision for informal recreation, specifically in relation to its recognition of the value of urban open spaces and their contribution to an urban renaissance. It is, however, urban biased and continues to overemphasise planning for formal sport and recreation at the expense of informal recreation. The objectives of the PPG outlined in paragraph 2 of the draft are vague and fail to recognise either the importance of providing, protecting and enhancing sport, open space and recreation in rural settings or the much greater significance of informal as opposed to formal recreation.

  3.  While we appreciate that the Sub-committee is principally concerned with urban affairs it is important to note that the draft PPG fails to deliver on key aspects of the Rural White Paper, specifically in relation to maintaining countryside character and tranquillity, and maximising the opportunities for quiet enjoyment of the countryside. It also underestimates the importance of informal recreation that has been so visibly confirmed by the recent foot and mouth outbreak and which is an order of magnitude more popular than formal recreation. Considering the important relationship that exists between town and country and the number of urban residents who utilise the countryside for formal and informal recreation, it is imperative that the wider impacts of this PPG are understood and explored.

  4.  The following answers are given in response to the questions posed by the Committee for consultation. Our recommendations and detailed comments are contained in the response we submitted to the DTLR's consultation draft PPG 17.

THE CONTRIBUTION OF THE REVISED PPG TO STRATEGIC PLANNING FOR SPORT, OPEN SPACE AND RECREATION

  5.  The draft PPG does not sufficiently inform strategic planning for sport, open space and recreation. It should identify clear criteria for incorporation in Regional Planning Guidance, Structure and Local Plans with regard to:

    —  the protection of existing open space and sport and recreation facilities;

    —  the improvement of existing open space and sport and recreation facilities;

    —  the provision of new open space and sport and recreation facilities;

    —  the improvement of access to sport and recreation facilities, open space and in the wider countryside as a means of recreation;

    —  resolving conflicts between sport and recreation, and with conservation and quiet enjoyment.

  6.  CPRE believes that the revised PPG falls short of its potential to ensure the strategic planning for sport, open space and recreation for the following reasons:

    —  in protecting existing provisions of open space the draft PPG 17 fails to recognise that open space can perform multiple functions even when its principle function is for formal recreation. It does not take account of the fact that the quality of provision is also influenced by the manner in which open spaces relate to one another, the level of linkage and variation in character. As such, the provision of open space cannot be evaluated in the way currently proposed in Chapter five and areas judged "surplus" by this method should not be assumed acceptable for redevelopment;

    —  the commitment in the draft PPG 17 to "provision and enhancement" is not delivered on. The revised PPG should identify clear criteria for when and how local authorities can instigate enhancement of facilities and open space eg by improving access to them;

    —  the draft PPG should highlight the role of local planning authorities in improving access to new and existing facilities and open space through sustainable transport eg improved bus routes and timetables, by providing safe cycling and walking corridors. It should also recognise the value of improving access and connectivity in the immediate countryside around urban areas;

    —  the wider implications of sport, open space and recreation on the environment should be considered and direction given on how conflicts between different forms of sport and recreation can be resolved (see below).

THE CONTRIBUTION OF THE PPG TO THE PROVISION OF HIGH QUALITY NEW OPEN SPACE AND SPORTS OPPORTUNITIES

  7.  The draft PPG 17 is disappointing in its lack of foresight for the role of local authorities in the provision of open space and sports opportunities. Chapter six concentrates on the provision of new facilities, largely ignoring the importance of providing new opportunities for informal recreation. In terms of ensuring new development is of a high quality CPRE's greatest concern is that it is sustainably located and has minimal impact on the environment around it.

  8.  While we welcome the criteria approach outlined in paragraph 41 of the draft PPG 17 CPRE believes this should also:

    —  set a wider context for the provision of all new sport and recreation facilities in line with paragraph 2.17 of PPG 7 ie new development should only be considered on greenfield sites where opportunities have been assessed for use of previously developed land—a sequential approach;

    —  require that new facilities should be located where sustainable transport links can be forged and accessibility maximised;

    —  recognise that some forms of non-built facilities may be inappropriate on greenfield sites where they impact on surrounding character and tranquillity;

    —  take adequate consideration of the significant impact of new recreational development on local character including the effects of lighting and noise;

    —  clearly state that stadia and major development are not acceptable in Green Belt and should not weaken Green Belt policy by ad hoc alterations to planning policy guidance without a full and public consultation to review PPG2 (which we believe is unnecessary);

    —  consider the impact of other new development on existing provision and ways of providing for the need that could be created by that.

THE EXTENT TO WHICH THE REVISED PPG IS SUCCESSFUL IN ADDRESSING THE NEWLY INCLUDED SUBJECT OF OPEN SPACE AND RECONCILING IT WITH SPORT AND RECREATION

  9.  CPRE believes that one of the main objectives of the new PPG on sport, open space and recreation should be to resolve the conflicts that arise between them through disputes over land use, disturbance and pollution. Local authorities need to plan strategically to ensure that conflicts are minimised and where possible avoided. This will be especially necessary in confined areas and on the rights of way network where conflicting interests may result in danger and public injury. In some cases local authorities will need to consider means to improve management of such areas, others will require the reallocation or improvement of existing provisions.

  10.  CPRE suggests that the revised PPG should:

    —  encourage local authorities with severe urban fringe problems to adopt management strategies to improve the provision of facilities and open space, minimise conflicts and maintain the character of these areas;

    —  provide guidance for minimising the impact of those activities which incur serious implications for land use, disturbance and pollution;

    —  consider how conflicts with quiet enjoyment and tranquillity might be reconciled especially where they are already competing with the intrusive nature of the urban environment;

    —  establish a presumption against the floodlighting of facilities where it unnecessarily impacts wider than its intended effect.

THE EXTENT TO WHICH THE REVISED PPG'S TREATMENT OF OPEN SPACE WILL CONTRIBUTE TO THE URBAN RENAISSANCE, THE PROTECTION AND IMPROVEMENT OF OPEN SPACE AND IMPROVED LIVING ENVIRONMENTS

  11.  CPRE welcomes the draft PPG's recognition of the role of urban space in quality of life (paragraph 3) and the multiple functions of informal open space (paragraph 15). We also welcome the promotion of improving the permeability of urban areas through increased linkage between open spaces (Chapter 6). But while we appreciate paragraph 16's recognition that "planning policies should take into account the respective roles of formal and informal facilities and open spaces to the fabric of an area and to the quality of life", we would like to see this concept expanded within the draft PPG.

  12.  In order to give full affect to the contribution of open space to the urban renaissance and improved living environments the revised PPG should:

    —  assess the importance of protecting, enhancing or providing new open space in terms of its entire contribution to local quality of life, not just its recreational value and not in comparison with the provision of other recreational facilities in that area;

    —  recognise that the true value of a site often goes beyond its recreational function and open space of the same nature may not easily be recreated. The concept of trading areas of open space is therefore complex;

    —  the concept of identifying surplus open space which may therefore be acceptable for development is inherently wrong and contrary to both the sequential approach advocated in PPG7 and the principles of urban regeneration.

THE CONTRIBUTION OF THE PPG TO ACHIEVING THE GOVERNMENT'S ASPIRATIONS ON URBAN PARKS AND PLAY PROVISIONS AS SET OUT IN THE URBAN WHITE PAPER

  CPRE has no comments to make on these sections.

September 2001


 
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