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Select Committee on Transport, Local Government and the Regions Appendices to the Minutes of Evidence

Memorandum by The House Builders Federation (PPG 22)


  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 In that respect, the draft guidance makes some very simplistic assumptions about the use of open space and recreational facilities and about the interchangeability of the various different types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.


  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 sites)

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" and elsewhere.


  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.

September 2001

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