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

Supplementary memorandum by The Institute of Leisure and Amenity Management (ILAM) (PPG 07(a))


  I understand from our conversation following the Committee Hearing on 23 October 2001 that I am able to submit a supplementary memorandum of evidence for the Committee's consideration. My reason for doing so is to give a more direct answer to the key question of just what a revised PPG: 17 could do to support the better management of urban greenspace systems. "Greenspace System" is my preferred term. It is in common use in the USA since Olmsted's creation of such systems for major American cities more than a century ago. It best describes the network of parks and green spaces of many kinds which weave their way across the urban landscape and which, in Britain, can account for as much as 20 per cent of the developed urban area.

  The reasons for seeking to address the management of the entire greenspace system in a planning policy guidance note are:

    —  planning should be making a contribution to improving the existing greenspace system, not merely adding open space;

    —  the benefits attributed to "open space" in PPG: 17 relate more to its quality than its quantity and cover not simply a wide spectrum of economic, social and environmental benefits but have a key role to play in addressing such "cross-cutting" issues such as healthier lifestyles, community safety and sustainable development;

    —  there is ample evidence (TCP Inquiry 1999, Public Park Assessment 2001) to show a sharp decline in the funding, quality and value of urban parks and green spaces which undermines the protection and enhancements sought by the planning system;

    —  the loss of greenspace to other development is frequently preceded by a deterioration in its quality;

    —  planning policy should be directed towards encouraging an "urban renaissance"; this means improving the quality of the urban environment, particularly in inner-city areas where development provides little opportunity to create new open space;

    —  Town Planning in Britain is substantially a reactive process and needs to be made an integral part of a corporate approach by local authorities to achieve the goals of urban regeneration.

  Planning Policy should be informed by an appreciation of the urban landscape, urban landscape heritage, urban ecology, civic culture and urban forestry, all depressingly absent in the consultative draft of PPG: 17. It should also be informed by developments in greenspace planning since the first PPG: 17 in such studies as "Open Space in London (LPAC 1994) and Accessible natural greenspace in towns and cities: A review of appropriate size and distance criteria (English Nature Research Report No 153: 1995) both ignored in the current consultative draft. Both would help to develop a better understanding of the inter-dependence of the planning and management of a greenspace system which is owned by the same local planning authority.

  The essential tool for bringing planning and management together is the greenspace strategy. In the recommendations of the earlier TCP Inquiry, this is referred to as a "Master Plan". Given the size and potential of this major asset base, and the loss of value due to its current neglect, the publication of a PPG is an ideal opportunity to make the preparation and implementation of such a strategy a requirement of all local authorities. Such a strategy would not in itself amount to supplementary planning guidance as too little of the content would impact upon planning decisions but it should inform other, area-based, supplementary planning guidance and be considered as a material consideration under section 54a of the Planning Act. It is worth noting that the key recommendation of the recent report of the Greater London Assembly's Green Spaces Investigative Committee is that the Mayor's Spatial Development Strategy should require all boroughs to have in place an open space strategy.

  It follows that it should be a requirement of the Department for Transport, Local Government and the Regions that they publish guidance on the preparation of such strategies in their intended companion document to PPG:17.

  The basic content of such a strategy should be:

    —  scope of the strategy including typology, quantity and distribution;

    —  quantitative and qualitative standards for provision and maintenance including design briefs for new and/or upgraded areas;

    —  evaluation of landscape quality both "designed" and "natural";

    —  the policy aims which should unite the purpose of planning and management;

    —  the market—an examination of the target populations, areas of deprivation, proposals for monitoring use and satisfaction;

    —  assess resources needed to sustain quality standards;

    —  identify resources and partnerships; and

    —  develop community involvement programmes for health, education and community development.

  Including support for such strategies within a revised PPG:17 would complement the aims of the PPG and help to bring planning and management closer together as is the case in many EU countries. There is, however, a limit to what Planning Policy Guidance can do. It cannot solve the deep rooted problems identified by the House of Commons Environment Sub-committee Inquiry into Town and Country Parks. To develop the skills and resources needed, support innovation and good practice, and sustain urban greenspace higher in the political agenda, there is no substitute for the creation of a national agency. Such an agency with similar resources and responsibilities to the national agencies operating in all other non-statutory sectors of local authority culture and recreation, most notably Sport England, would inform both local and national government, including on their planning responsibilities. This was a clear recommendation of the earlier House of Commons Environmental Sub-committee Inquiry into Town and Country Parks and, in my view, should be reiterated in the context of the present inquiry.

  Section 106 agreements should also ensure that planning and management work together better for the protection and improvement of the greenspace system. Planning gain would often be better directed to sustaining and improving existing green spaces than adding new spaces. It is also essential that the calculations made by planning authorities both for the cost of good quality provision and for a commuted sum for its future maintenance are realistic and achieve their purpose. The Urban Affairs Sub-committee may wish to consider both points for recommendation in their report. However, this still leaves the question of support for green spaces via Section 106 competing with other demands, particularly the inclusion of social housing. There is also the inequity which exists between those areas able to make such demands of developers and those, often more deserving, who cannot.

  The requirements for "Best Value" apply equally to both local authority planning and management functions. They should be used to get better value from a closer integration of planning and management of urban green spaces. I regret the use of Best Value Performance Indicators for planning which concentrate on the speed of decisions, rather than their quality and beneficial outcomes. Britain's urban areas are so blighted by poor planning decisions that we are now deemed to need an "urban renaissance". Better to develop a range of voluntary indicators, shared and compared by local authorities, which concentrate on beneficial outcomes, and the efficacy of the process rather than its speed.

  In summary, I hope the Committee will be able to influence a revision of the draft PPG:17 to better reflect the goal of an urban renaissance, giving greater emphasis to the improvement of existing provision, upholding quality over quantity, and the integration of the planning and management of the greenspace system. It follows that the emphasis on provision for sport in the present draft is misguided and that the PPG should be re-titled to celebrate the diversity of green spaces within the urban environment and their many benefits of which encouraging greater participation in sport is but one. Failing that, PPG:17 should confine itself to "sport and recreation" as defined by Sport England and leave the more important issue of conserving and enhancing the greenspace system to a new PPG, possibly devoted to the urban landscape or the public realm. This would seem far more germane to the quest for an urban renaissance than the present document.

November 2001

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