Memorandum by The House Builders Federation
1. The House Builders Federation is very
grateful for the opportunity to submit a memorandum of evidence
to the Urban Affairs Sub-Committee of the House of Commons Select
Committee Inquiry into the Draft PPG17: Sport, Open Space &
Recreation. The House Builders Federation (HBF) is the voice of
the house building industry in England and Wales. The industry
is highly diverse and HBF's members' range from large, multi-national
companies to small, locally based businesses. Together, they build
over 70 per cent of new homes in England and Wales each year.
2. Whilst the HBF welcomes the update of
PPG17, which is now approaching ten years old, and is supportive
of some aspects of the revision, it also has a number of concerns.
Not least, with regard to a lack of clarity and consistency within
the document and, in particular, inconsistency with other government
guidance and legislation.
3. Specifically, there is a lack of clarity
of definition throughout the document. There is no allowance for
any flexibility in the loss of open space or recreational facilities
and insufficient importance is attached to the location of and
local use of facilities. In that respect, the draft guidance makes
some very simplistic assumptions about the use of open space and
recreational facilities and about the interchangeability of the
various different types of open space and recreational facilities.
4. Overall, there is a failure to recognise
the aims and objectives of PPG3, Housing and no acknowledgement
of the importance of quality and design in the provision or retention
of facilities. To this extent it is likely to work against other
government policy objectives to achieve the urban renaissance.
5. This submission does not repeat, in detail,
all of these matters as they are covered adequately in the HBF's
original representations on the draft PPG. Rather, in accordance
with the specific areas of interest of this Select Committee,
it focuses on this latter issue of consistency with broader government
objectives. Namely those objectives of PPG3 to achieve high quality
sustainable new living environments which will improve peoples'
quality of life and assist in achieving the urban renaissance.
PPG3 & ACHIEVING
6. PPG3 requires development to be concentrated,
in the main, on previously developed and urban land before greenfield
sites are developed. It requires the best use to be made of development
land and encourages high density development allied to high quality
and well designed dwellings and attractively laid out sites.
7. This is a major challenge for house builders
because of the nature of brownfield sites, the difficulties and
cost of their development and the perceived lack of demand from
the general public for such a product. However, in spite of these
difficulties, house builders have risen to the challenge and are
producing quality developments which accord with all these aspects
of government policy. Yet, in spite of the serious implications
of the provisions of the draft PPG17 (discussed below) on the
future use of urban land, the relationship between the requirements
for the retention and provision of facilities for sport, open
space and recreation in draft PPG17 and the PPG3 agenda is not
recognised in the draft PPG.
8. There is only a limited amount of brownfield
development land available within urban areas. There is concern,
therefore, that PPG3 targets and aspirations of:
(i) providing 60 per cent of new housing
on previously developed land by 2008; and
(ii) applying a sequential approach to the
location of new housing development (whereby previously developed
and urban land is developed before more peripheral and greenfield
will be frustrated if recreation facilities are also
competing for the same scarce resource.
9. PPG3 receives only scant mention in the
draft PPG. The only significant mention is at paragraph 49 and
even this is erroneous. What paragraph 49 states is that local
authorities should review all non-housing allocations when they
come to review their development plans with a view to considering
whether they could best be re-allocated for housing. It then states
that, if there is surplus employment land identified it should
first be considered for housing and if that is not acceptable,
recreational use should be considered.
10. The relevant section of PPG3 (paragraph
42), however, says no such thing. Whilst it does say that all
non-housing allocations should be reviewed it does not mention
sites being allocated for recreation or open space use. It must
also be borne in mind that any review of existing non-housing
allocations would also, by definition, include a review of open
space allocations. If those allocations are deemed to be unrealistic
then, according to PPG3, consideration should be given to re-allocating
them for housing or mixed use in order to achieve the aspirations
of the urban renaissance policies propounded in PPG3 which seek
to make the best use of previously developed and urban land.
11. This inconsistency should be redressed
both in terms of this specific point, but more importantly in
terms of a much greater acknowledgement of the aims and objectives
of PPG3 in the draft guidance. Not least recognition of the need
to make the best use of urban and brownfield land, but also in
terms of quality and design matters as set out below.
12. It is in all our interests, house builders,
government and local authorities alike, to strive to achieve the
aspiration of an urban renaissance and to create attractive urban
environments. Creating high quality developments is not about
the quantitative amount of open space which is provided per se.
Rather it is concerned with the use, arrangement, layout, quality
and design of that space and its relation with buildings and other
amenities. Less, can certainly be more, in the context of incorporating
open areas in high quality, high density sustainable urban developments.
13. The draft guidance needs to incorporate
this design agenda into its remit. It needs to address the issue
of the use of existing and new open space in new urban developments.
It must recognise that traditional quantitative and mechanistic
solutions to calculating the type and amount of open space or
sports facilities to be provided may not be the prime consideration
in seeking to achieve an urban renaissance. It needs to draw on
the general advice on these matters in PPG3 and more detailed
guidance given in the PPG3 Good Practice Guide "By Design"
14. The Federation welcomes measures in
the draft PPG which require local authorities to assess local
needs for recreation, open space and sporting facilities and to
protect those which are clearly valuable, important or meet identified
needs. The Federation also accepts that the provision of new open
space and facilities is a vital element in creating attractive
living environments and achieving the urban renaissance. House
builders therefore welcome the bullet points 5, 6 & 9 under
paragraph 5 and the relevant sections of the draft guidance which
develop these ideas. HBF also agrees wholeheartedly with the statement
at paragraph 25 that open space and recreation facilities should
not be retained in all circumstances.
15. The problem for developers is the inconsistency
in the document between these general statements and more detailed
guidance contained elsewhere which makes it clear that protection
of open space, at all costs, is precisely what is being advocated.
16. Only when trying to work through the
guidance to find circumstances where it may be appropriate or
acceptable to develop areas of open space or sports facilities,
does it become apparent that such circumstances simply do not
exist. These inconsistencies must be eradicated by the incorporation
of the changes suggested in this representation in the next draft
of the PPG.
17. Overall, therefore, while the revision
of PPG17 is welcomed in principle, as currently worded the draft
leaves a lot to be desired. It is considered by HBF to be overly
restrictive and negative, limited in focus and application, unclear
in its use of terminology and definitions and inconsistent in
approach both in itself and in terms of achieving the aims and
objectives of other aspects of government policy. Particularly
those objectives aiming towards an urban renaissance.
18. Whilst the document is supposed to be
a revision of the previous PPG17 ie to be forward looking and
reflect current and emerging issues of concern, it does not really
achieve this. Nor does it add anything to the existing PPG17.
In many ways, in creating confusion in the process and by the
lack of recognition of other government policy objectives, it
is actually a step backwards from the existing PPG17.
19. The draft requires substantial revision
to address the areas of concern highlighted above and to ensure
consistency with broader government objectives. It was HBF's formal
submission on the draft PPG that this revision should not be undertaken
by Civil Servants in isolation from the day-to-day problems of
implementing its proposals which would undoubtedly be experienced
by practitioners. The HBF called for a collaborative review of
the draft guidance and therefore very much welcomes the fact that
this Select Committee Inquiry is taking place.
20. HBF therefore hopes that the Select
Committee will find these additional submissions helpful and is
happy to have been of assistance to Committee Members.