Examination of Witnesses (Questions 1-19)|
TUESDAY 16 OCTOBER 2001
1. This is the first session of the Select Committee's
inquiry into the draft PPG17, Sport, Open Space and Recreation.
Can I begin by thanking all those people who sent in a memorandum
to us; the memoranda are now published in this House of Commons
document, and probably, for most of you, more usefully, they are
available on the House of Commons web page. So not only can you
see again what you sent in as evidence but you can see what other
people sent in, and we hope that will encourage a discussion outside
the Committee; in some cases people may even want to write in
commenting on other people's memoranda, and we would welcome that.
This morning can I welcome the four of you and ask you to identify
yourselves, for the record, please?
(Sir Neil Cossons) I am Neil Cossons,
Chairman of English Heritage.
(Mr West) Jeff West, Director, Conservation Management,
(Mr Coleman) David Coleman, Director of the Countryside
(Dr Harding) Stewart Harding. I lead for the Countryside
Agency on parks and open spaces.
2. Do any of you want to say anything by way
of introduction, or are you happy for us to go straight to questions?
(Sir Neil Cossons) I am happy, Chairman.
(Mr Coleman) We can go straight on, Chairman.
3. I understand that perhaps you are all quite
pleasedand I am directing this question, basically, to
the Countryside Agency, but, the others, please come inthat
open space has been made the subject of planning policy guidance.
Do you think that sufficient open space is treated successfully
and clearly in the new PPG?
(Mr Coleman) No, I think it is inadequately treated.
I think we welcome many of the specific proposals, and I can come
on to the detail if you wish, but standing back and taking the
PPG as a whole we do not think it deals adequately with open spaces.
There is clearly a major problem in the range of recreation and
resource and site and that huge range of material that it attempts
to cover, but we believe it does not succeed in covering it adequately.
And I suppose, if I were to pick on one reason for that, it is
because it is far too driven by the activity, whether it is recreation
or sport, or whatever, and that leads to great difficulties, and
ultimately, I believe, inadequacy, in dealing with the more resource-based
issues that arise in relation to open spaces.
(Sir Neil Cossons) And we have the same view, that
it is inadequately dealt with in the framework of the PPG. The
nature of open spaces is so diverse, in terms of the particular
qualities relating to them, that to handle them within the framework
of a PPG is particularly complicated anyway. So, although the
PPG is in one sense the right place to have a strategic overview
of how open space should be dealt with, for the reasons just set
out that tends not to be the case, and therefore open space falls
through the net.
(Dr Harding) Could I add to that. If, like me, you
have got a long background in the promotion of parks and open
space, the PPG actually strikes a very discordant note in the
way it presents open space issues. My view of it is, I know how
the PPG was conceived and I know how it evolved from earlier PPGs,
but in terms of public interest and public involvement there is
no doubt that open space is a much more important issue to more
people than sport, for example, and, the way the PPG is presented,
it tries to make open space a subset, I think, of sport and recreation.
And I think therein lies the major difficulty with the way the
PPG has been drafted, that open space is an extremely important
topic on its own, and to have it tacked on to the end of sport
and recreation issues I think misses the point. And you can appreciate
what I am trying to say if you turn the title of the PPG round,
to reflect public interest, to say that the PPG maybe should be
called Open Space, Recreation and Sport. Open space is a resource,
sport and recreation are activities, and when you look at it like
that and say open space, recreation, sport, you do have to ask
the question, well, why sport, why not open space, recreation
and play, or open space, recreation and music, or open space,
recreation and events; because these are all things which open
space does, and the open space does it as much for those things
as it does for sport. So I think that inherent flaw in the drafting
actually presents all of the difficulties.
Sir Paul Beresford
4. Looking at it from another point of view,
would you not say that what you have just said is really a poor
reflection on this country? Here we are, where we are currently,
the All Blacks always beat England, or almost always, Australia
manages better Olympics; the southern hemisphere's attitude to
sports is reflected in their successes. If you look at the population
of those nations and look at the population of this nation, if
you look at our sport success, what you have said is a very sad
reflection, and perhaps we ought to have a different attitude
towards sport, and therefore a better use of the open spaces that
(Mr Coleman) If I could answer that. There is no question
about sport being important and sport raising many important planning
issues that need to be dealt with in a PPG; we were addressing
the specific point about why is open space dealt with badly in
this PPG, and that is about structure, we can come on to what
some of the solutions might be in a minute, but that is about
structure and confusion in the way which it is dealt with.
5. Do you think that there exists an adequate
methodology to plan for open spaces and informal recreation which
the PPG could promote?
(Mr Coleman) Perhaps I could ask Dr Harding to comment
on that; it comes from all of his experience.
(Dr Harding) I think we do need a methodology, because
I think the other major problem with the PPG is that it is not
contextualised in terms of the problems facing parts of open space
and recreation space; and local authorities need as much guidance
as possible on how to do better with their parks and open spaces.
We have got the old standards which are largely seen as old-fashioned
and fairly meaningless. I think the Agency would prefer quite
a loose definition but something which appreciated in a wider
way people's use of open space, so that we would like a standard
which said people should have access at no more than, say, 500
metres from high quality open space, and you could bring into
that view the time it takes to get there, or the difficulty it
takes to get there, or whether the open space is actually safe
and attractive when you do get there.
6. Is that realistic? There is no point putting
something into planning guidance that is not realistic. You think,
really, that distance from people's home there should be some
open space is realistic?
(Dr Harding) Clearly, it is an idea, but I do not
see any problem with the PPG being aspirational, in that sense.
If you try to be realistic, in your sense, you will end up with
the lowest common denominator, that which is achievable, and I
do not think that serves the purpose either.
7. Do you believe that there exists an adequate
methodology, is that what you are saying?
(Dr Harding) There is an awful lot of work to be done
on this. There could be an adequate methodology, but it needs
an awful lot of work by an awful lot of different agencies to
produce it, and in some ways the draft PPG is pie in the sky in
the way that it talks about we need this, that or the other, when
we actually know that local authorities are having great difficulty
even managing and delivering what they have got. Somebody needs
to do a methodology, somebody needs to make definitions of parks
and open spaces, and somebody needs to define standards; at the
moment there is nobody there to do that job.
(Mr Coleman) A distinction it might be helpful to
make is between standards and benchmarks; standards may be the
wrong word, because of the variability and the diversity that
is needed in this situation, but certainly we think there is enormous
value in the Government leading, and a PPG is a good place to
do it, in establishing benchmarks, what would be good provision,
what would be medium provision, what would be poor provision.
Now you could describe it as a standard or a benchmark, but it
would give a framework within which local authorities could then
8. Sorry, I was so interested in following up
the little exchange that just took place, and I think it does
lead on to what I was going to ask about, which is about formal
open space strategies; and whilst I come from the point of view
that I very much want us to improve our sporting standards, and
I am a bit of a sports fanatic myself, I have to say that most
of my constituents write to me wanting open space, not necessarily
formal sporting provision. Given that, I certainly think we need
more formal open space strategies. I am directing this remark
to English Heritage. We were slightly surprised to see that you
appear to come out against such formal strategies, and, as we
received a number of memoranda that do the opposite, although
we understand what you are saying about strategy overload, and,
indeed, we were hearing earlier how local authorities are actually,
what was the term, 'overstrategising and underdelivering'. We
do think that if there is to be a rational approach to open space
provision it does need to be within a strategic framework; would
you not agree?
(Sir Neil Cossons) We would agree; and I think our
anxiety was that to have a free-standing open space strategy which
was not locked into the wider spatial development strategy that
a local authority would be expecting to develop would actually
be to lose the game. There needs to be strategic thinking for
the protection of and provision of open space within local authority
areas, and within the context of a PPG, which is a planning document,
it therefore needs to be locked into the wider issues of planning
development and spatial strategy.
9. But do you think that developing these formal
strategies should be mandatory?
(Sir Neil Cossons) Parks and open spaces are not a
mandatory responsibility of a local authority, but they exist
and local authorities have responsibilities for them; and one
of the difficulties, I think, is that there is no natural champion
within a local authority for open space. If you look at the way
in which local authorities care for their open spaces, open spaces
fall within a wide variety of departments; there is no common
formula or pattern across the country. That indicates, to me,
that local authorities do not know what to do with their public
open space; because they are not a statutory responsibility it
is easy for them to fall off the end of the shelf when other funding
and strategic priorities are pressing. And you can see that, I
think, in the decline in the funding that local authorities have
spent on open spaces over the last 20 years, or so.
10. If you are correct, that local authorities
do not really know what they are doing with their open space,
then is it not all the more important that local authorities themselves
are actually forced to try to come up with a strategy, as opposed
to, say, relying on what you were talking about earlier, which
was benchmarking; although there is a place for that, surely it
is not sufficient?
(Sir Neil Cossons) It seems to me that there are two
issues. One is, within the framework of a PPG, that is a planning
framework and public open space should have a strategic place
in the planning thinking of a local authority. The other side
of that coin is that local authorities properly look after the
public spaces for which they have responsibilities, and that implies
benchmarking, standard-setting and some mechanism whereby local
authorities can then be assessed in their performance as guardians
of public open space. It is something to which, for example, the
Audit Commission could take note, either through best value or
their other procedures.
11. Could I press you a little bit on this.
What you seem to be saying is that a strategy is a necessary but
not a sufficient condition of the good development of open spaces,
and you are fairly diffident about strategies. Now, is the reason
that you have a degree of cynicism about the way in which strategies
may be related to resources, or is your view, alternatively, not
that but that the strategy itself may be too prescriptive and
too hampering in what it may achieve?
(Sir Neil Cossons) The need for a strategy within
the planning process, it seems to me, is self-evident, as long
as that strategy is locked into the wider spatial development
strategies which guide that planning process; and there ought
perhaps to be presumptions against development which will protect
areas of public open space, and those presumptions should be established
and set out within the overall planning strategy for a local authority.
But there is a discontinuity between that strategic desire to
define and, in theory, protect public open space and the technical
ability of the local authority to deliver the sorts of quality
of protection that is necessary.
12. It is the scope of the strategy that is
(Mr West) If I may. We are absolutely clear, I think,
that there needs to be a strategic approach to open space taken
by local authorities. The problem at the moment is that local
authorities are being asked to prepare, or help facilitate, so
many different strategies, to a large number of which open space
is absolutely critical, whether it is the community strategies
that are being prepared by Local Strategic Partnerships, whether
it is Local Plans, or whatever will emerge from the Planning Green
Paper, later this year, to replace the current Local Plan process.
Open space is critical to all of these, and a strategic approach
needs to be taken. The critical thing is that they be joined up.
We do not want a free-standing strategy that is just put on the
shelf. It needs to be embedded in the whole range of thinking
about local areas.
13. You suggest in your memorandum that PPG17
fails to serve as "one of the keys to the urban renaissance
promoted by the Urban White Paper". Would you like to tell
the Committee why you think this, and expand upon why you believe
this has been "a missed opportunity"?
(Sir Neil Cossons) Yes. I think the PPG17 as a guideline
within which we can contemplate public open space fails to establish
the broad generic case for open space, and I come back to the
point made earlier, that it seems to me that we are looking at
public open space as the first order issue here, and the second
order issues are the nature of the values that attach to those
open spaces in the eyes of the communities they serve and the
uses to which they are put, whether they are recreational or sport,
or whatever. And it seems to me that we do need to turn the argument
over and recognise that public open space is a good in its own
right, that it has various qualities attaching to that good, and
that needs to be set out as a central plank of our approach to
public open spaces within the planning system.
(Dr Harding) I think the problem is this dismal expression
'open space' which sounds like an absence of anything, and when
that expression gets embedded into planning jargon, why do we
not call them something much more positive.
14. Such as?
(Dr Harding) I thought of this on the train today:
recreational and pleasure grounds; they are positive attributes,
they have positive uses and people treat them positively, given
half the chance. If we call them 'open space' it sounds like they
are up for grabs for anything.
15. What does a central reservation on a dual-carriageway
count as; does that count as open space, or is that part of the
(Mr Coleman) You raise a serious point, if I can just
intervene, which is that it is an example of where the PPG gets
kind of part of the argument right. I cannot remember which the
chapter is, but it defines informal open space, and it draws that
definition extremely broadly to include historic importance, to
include wildlife, but it does not deliver that throughout the
whole document. So there is a recognition there that open space,
as has just been pointed out, is the baseline resource, the overarching
resource, but it does not follow it through in its proposals.
16. I would particularly like to ask the Countryside
Agency why you believe that insufficient emphasis is placed on
urban parks; what do you feel, looking at urban parks in particular,
what should the guidance say?
(Dr Harding) A tricky one. This goes back to the way
the PPG was drafted. The impression given of open space, despite
the definition in the footnote on the first page, is that open
space is being regarded, if recreation is a subset of sport, it
reads like recreation is sport for fat kids and open space is
the other stuff, which is not even informal recreation. Public
parks are a hugely important part of our daily life, massive numbers
of visitors, five million visitors, to St James's Park; now that
is exceptional, but an average, traditional, urban park in this
country will have between 100,000 and 350,000 visitors a year.
Now that is a huge thing. This PPG is silent on all the thousands
of aspects in which urban parks contribute to the quality of our
daily life. And they are still under pressure, they are under
pressure from neglect, they are under pressure from underresourcing,
but they are also under development pressure, too, and they are
regularly being changed for the worse, and PPG does not say anything
about that. So urban parks deserve a PPG almost in their own right,
I would suggest.
17. Why did you draw an analogy with St James's
Park? I would have thought that could have been used as a throughway,
a way through?
(Dr Harding) It was just an example.
18. Is it a good example though, looking at
St James's Park?
(Dr Harding) It is a park of the quality that most
towns would aspire to, but it is also a park of the quality that
most towns had 30 years ago.
19. A question to English Heritage. Specifically,
how do you think that the PPG can address issues of management,
maintenance and design?
(Sir Neil Cossons) It comes back to the question of
whether the PPG is the right framework within which to consider
management issues. It seems to me that we can define within a
PPG the qualitative need for open space, we can define the nature
of the activities that define that open space, or, indeed, the
particular qualities, be they ecological, to do with biodiversity,
or to do with historic landscapes and buildings. One thinks, for
example, of Sefton Park, in Liverpool, and Birkenhead Park, just
across the water, as examples of historic parks which have encouraged
similar developments all over the world; they need, therefore,
to be protected as part of the wider heritage. All of that, it
seems to me, is the legitimate area of a PPG. There could well
be, attaching to that, however, guidance on how a local authority
might look after its public open spaces; in our case, we would
be interested in historic parks, in particular, with examples
of good practice, and attaching to them some benchmark standards.