Memorandum by Commission for Architecture
and the Built Environment (CABE) (PPG 26)
REVISION OF PPG 17SPORT, OPEN SPACE
1. The Commission for Architecture and the
Built Environment is an Executive Non-Departmental Public Body,
established by the government in 1999 to promote high standards
in the design of new buildings and the spaces between them. Its
remit covers England.
2. CABE is a non-statutory consultee in
the land use planning system. It is funded by grant-in-aid from
the Department for Culture Media and Sport, with additional resources
from the Department for Transport, Local Government and the Regions.
3. Commissioners are appointed by the Secretary
of State for Culture Media and Sport. They are drawn from a range
of areas of expertise and include architects, planners, an engineer,
a quantity surveyor and specialists in the field of housing design
and built environment education.
4. Some of CABE's day-to-day work is undertaken
by committees, including a design review committee and an enabling
panel. The design review committee offers advice to planning committees
and others on the design of strategic development projects. The
enabling panel offers advice to clients in the public and private
sectors who aspire to quality but would welcome technical assistance
on matters such as brief development, selection of architects
and choice of procurement route.
5. This memorandum of evidence relates to
the design and planning of sport, open space and recreation provision,
and in particular, the proposed content of revised Planning Policy
Guidance Note 17.
6. CABE considers that there is much to
commend in the revised guidance note:
recognition that open space works
as a network, defining and separating urban areas, providing a
permeable grid of functional and recreational opportunities, and
meeting the needs of both people and wildlife;
the emphasis on design quality of
recreational facilities and open space, linked to "By Designthe
Companion Guide to PPG1";
support for multiple use of community
facilities, such as school sporting facilities for the use of
the wider community;
recognition of the legitimacy of
requiring recreational and open space provision through Section
106 agreements; and
emphasis on the direct relationship
between the design and management of open space.
7. CABE would therefore wish to express
general support for DTLR in its intentions evidenced through the
draft guidance. There do, however, remain a number of weaknesses
which are the subject of this submission.
8. The overarching problem with the draft
guidance note is that it fails to reflect the complexity and diversity
of recreational and open spaces needs within our urban areas at
the start of the twenty first century. The residing impression
is a view of the world that is quaintly old-fashioned, somewhere
between John Major's vision of warm beer and village cricket pitches,
and a track-suited Brian Glover patrolling the bleak inner-city
football pitches of the 1970's film "Kes".
9. 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, cafe seating areas etc etc.
10. The guidance note fails to reflect or
even recognise this richness. This is evidenced as early as paragraph
3 of the guidance note in providing a definition of the content
of the guidance note which is limited to ". . . parks and
other informal green spaces". Many urban spaces are not green
at all. Nor should they be. They will be "hard" spaces
of the quality of Birmingham Victoria Square or Leeds Millennium
Square. The hardness of these spaces does not in any sense diminish
their importance and they need to be embedded within the scope
of the guidance note.
11. The second general principle is that
the guidance fails to recognise adequately the regeneration role
and potential of well-designed public space in terms of its positive
fostering social inclusion;
reducing crime and fear of crime;
generating economic use and value
(see CABE research report 1"The value of urban design",
for empirical evidence on this theme).
The guidance should state at the outset that
it is the proactive responsibility at planning authorities to
ensure that this regeneration potential is realised, linked to
local authorities' overall statutory economic, social and environment
duty in administering their area.
12. The third overarching point is that
the guidance note needs to accentuate more the importance of quality
of provision as well as quantity. It is for this reason that CABE
opposes the imposition of strict standards on the quantum of public
space provision in any given area. While the local planning authority
must take an overall view on user needs and desired outcomes,
there should be flexibility for developers and designers to use
their creativity and innovation to design facilities and spaces
that meet those needs efficiently.
13. To this end, CABE would welcome the
guidance setting out some key design principles that would include:
the relationship between space and
the contribution of open space to
movement frameworks and legibility;
the relationship between private
and public space;
designing for natural surveillance
and crime reduction; and
14. While these principles are set out clearly
in the companion guide to PPG1 there needs to be a summary articulation
in PPG17, rather than relying entirely on cross-reference to what
is only a companion guide.
15. PPG17 should also explicitly recognise
that public space design is a highly complex professional skill,
and should be undertaken by professional architects, landscape
architects and engineers, in close consultation with clients,
user groups and the local community.
16. In its final report, Towards an Urban
Renaissance, the Urban Task Force recommended that ".
. . all local authorities prepare a single strategy for the public
realm and open space, dealing with provision, design, management,
funding and maintenance". The importance of this recommendation
was underlined in earlier discussion within the Task Force report
which is worthy of reproduction:
"Safe, well maintained, attractive and
uncluttered open spaces provide the vital "glue" between
buildings and play a crucial role in strengthening communities.
But not all public space in English towns and cities is like this.
Some urban areas have too much public space, much of which is
poorly designed, managed and maintained. Many twentieth century
residential developments have a public realm which is simply "SLOAP"
(Space Left Over After Planning)soulless, undefined places,
poorly landscaped with no relationship to surrounding buildings.
A key task in these areas is to reconfigure public space so that
all parts of the public realm contribute toward achieving a high
quality environment." [page 57]
17. CABE's work over the last 18 months
has backed up the Task Force's analysis. To cite just two examples,
East Manchester has vast quantities of open space but no urban
structure. The loss of 80 per cent of its population over a century
combined with widespread dereliction has left a landscape that
has no coherence and which cannot promote successful urban regeneration.
East Manchester is starting to be regenerated but still in the
absence of any coherent public realm strategy. As a result, there
is a strong danger that individual interventions such as the new
Commonwealth Stadium, the Ask Business Park and the new Walmart
will not be integrated in a coherent townscape.
18. In Gateshead, a similar problem persists.
The city is now undergoing rapid regeneration fuelled by the new
Millennium Bridge, the Baltic Flour Mill restoration and the new
Lottery-funded music centre. Other developments are under consideration.
However, there is again no coherent public realm strategy as to
how each of these developments will relate to one another, with
a grave danger of potentially attractive public routes and spaces
being wasted through lack of forethought and poor design.
19. At the same time CABE realises that
there is a proliferation of local strategiesthe community
plan, the transport plan, the development plan etcand adding
another burden onto local authorities is not necessarily realistic.
However, there is no reason why PPG17 cannot advocate that local
planning authorities draw up public realm or landscape strategies
for specific regeneration areas followed by adoption as Supplementary
20. CABE finds draft PPG17 over-simplistic
in its approach to the location of new sport and recreation facilities.
Towns and cities are made up of networks of town centre, district
centres, neighbourhood centres and local hubs. The ability of
each of these different centres to accommodate facilities depends
upon the density of population, public transport access and competing
uses. Thus, for example in paragraph 5 of the draft guidance,
it may not be necessary to locate the most intensive recreational
activities in the town centre. A gym or swimming pool may be more
conveniently located in a district or neighbourhood centre.
21. On the design of the new facilities,
more explicit guidance is required. CABE has seen several examples
of schools facilities that were intended to be designed for competitive
community sports use but where the design of the facility failed
to meet competitive standards; sports halls not long enough to
accommodate five-a-side football, basketball courts with inadequate
run-off areas, badminton court areas with insufficiently high
ceilings. PPG17 should make clear that it is the responsibility
of the local planning authority to ensure that new facilities
meet the standards clearly set out by Sport England in their design
22. PPG17 should also emphasise more strongly
the potential for multiple use of facilities. For example, most
facilities should be able to accommodate active ground-floor uses
including related retail, childcare provision and other local
23. Over the last couple of years, CABE
has been directly involved in assisting local authorities managing
the development of major new facilities. Our experience has included
the new Arsenal and Everton football stadiums, Nottingham ice
stadium, the proposals for the new Wembley stadium and the aborted
plans for the new athletics stadium at Pickett's Lock. Based on
the lessons we have learnt, there are a number of key principles
that should be articulated within PPG17:
the problems of these facilities
becoming "dead spaces" outside of major events and the
need to ameliorate this problem through a mixed use approach;
the importance of insisting on a
high quality design for what will be landmark facilities, including
generosity of the public spaces around the facility;
the importance of designing the facility
within the context of an overall masterplan for the area, including
the careful relocation of any displaced uses; and
the establishment of the facilities
as integrated transport nodes in their own right.
24. The specific needs of young people are
a serious missing ingredient in the guidance note, which elsewhere
talks specifically about needs of children and those with limited
mobility, but fails to address young adults as a population group
which is often time-rich and cash-poor, and therefore heavily
reliant on provision of open space and other recreational facilities.
Many of the open space uses that they require such as skateboard
parks and street hockey courts are hard to integrate with community
life. It is important that the guidance provides some practical
advice to planning authorities on how to manage this provision.
It is a difficult but not impossible design challenge.
25. CABE would wish to see the guidance
strengthened in the following two specific areas:
Local plans: There should be
greater recognition of the linkages between public space provision
and local transport plans.
Design advice: The guidance note
should be explicit in pointing local planning authorities towards
expert organisations such as CABE, English Heritage and Sport
England in seeking design advice at the earliest stages of a project.