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

Memorandum by Commission for Architecture and the Built Environment (CABE) (PPG 26)



  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 Design—the 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 role in:

    —  fostering social inclusion;

    —  reducing crime and fear of crime; and

    —  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 buildings;

    —  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

    —  enhancing access.

  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 strategies—the community plan, the transport plan, the development plan etc—and 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 Planning Guidance.


  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 guidance.

  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 facilities.


  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.

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