Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by The Garden History Society (PPG 03)

  1.  The Garden History Society is the national amenity society for the study and protection of historic parks and gardens. It is a statutory consultee on planning applications affecting sites on the English Heritage Register of parks and gardens of special historic interest. PPG 15 states that the Society "has more experience of dealing with planning applications affecting parks and gardens than any other body" (paragraph A16).


  2.  This PPG offers the principal opportunity to capitalise on the major re-evaluation of the importance of public parks in the wake of the Select Committee report on town and country parks (1999) and the Urban White Paper (UWP) (2000). It is highly desirable therefore that the PPG specifically addresses the contribution parks make to the quality of life, to local distinctiveness and to the aims of sustainability.

  3.  That contribution is different from other forms of open space and from other forms of recreation facility. It is essential that the PPG sets out and employs a reasoned terminology and typology in dealing with what may be related but are in fact fundamentally different resources.

  4.  It is unfortunate that the PPG emerged just as the Government's Urban Parks and Green Space Taskforce began its work. We believe that it would be preferable to wait for the Taskforce to report and incorporate its findings in the PPG than to rush out what at present is a fatally flawed document. If the Government is determined to rush ahead with publication, we strongly advise that an interim Annex on parks be prepared for the PPG, flagging up the emergence of further Government advice on parks in the wake of the Taskforce report.

  5.  Turning to specific faults in the draft, which affect its ability to deliver on strategic planning for sport, open space and recreation, there is a fundamental flaw in the document's erratic terminology and lack of definitions. For example in paragraph three, the second sentence refers to "sports facilities, parks and open . . . spaces", but by the end of the paragraph the subject of the paragraph has changed to "sport and recreation facilities".

  6.  The phrase "recreation facilities" is never defined and as a result confuses facilities comprising buildings, with facilities comprising open space.

  7.  "Open space" needs to be unpacked and its various aspects carefully defined. It currently appears to include a vast range of spaces which, although sharing the basic test of being of "public value", have entirely different management and planning requirements. It appears to include such differing types as nature reserves, hard-paved town squares, amenity grassland, playing fields, canal sides, skate parks, kickabout surfaces, urban parks and public gardens, and allotments.

  8.  "Recreation" also needs to be broken down, and carefully defined. Since the original PPG 17 which signally failed to address other forms of open space enjoyment, "recreation", is widely inferred to mean sport. In paragraph two we are told that the government objectives relevant to this PPG are only those for "sport and recreation", omitting open space. "Recreation" must be defined as clearly encompassing both formal recreation (ie formal sport, and possibly formal play using equipment and defined play areas), informal recreation (informal sport and play, walking) and passive recreation (sitting, chatting, bird-feeding, admiring flowers, etc).

  9.  The phrase "informal open space" is introduced at paragraph 14, but nowhere is it defined, or distinguished from "formal" open space: no one can guess what it means. We are genuinely unclear what this means: kickabout areas, marginal land, public parks? We believe that a rigorous terminology is absolutely essential in a PPG. Urban parks, botanical gardens, country parks and cemeteries for example are "formal open space" in the physical sense: intensive horticulture and design, built structures, path networks, designated areas for different activities, and by-laws; but possibly "informal" in the uses they accommodate.

  10.  We also believe that a category should be identified to cover hard landscape such as urban plazas and piazzas; this could be termed "grey space", or "civic space" for example.

  11.  The draft PPG fails to provide sufficient clarity because it does not identify the special importance of parks as distinct from other kinds of "recreational facility". The contribution of public parks and gardens is qualitatively different from, and affects a far greater proportion of the population than, that made by sports facilities. Indeed the two can often be in conflict: sports development can detract from the cherished qualities of an urban park, by physically developing part of the park, and by eroding the tranquility which is often a park's most valued characteristic. It is absolutely essential therefore that the flawed conflation of the two, running throughout this draft, is corrected.

  12.  The PPG not only needs to sort out definitions internally, but it needs to make definition of open space the subject of its guidance to local authorities, and it needs to ensure that such definitions are made to nationally consistent standards—the PPG is the best place to set out such definitions and standards (see 18 below).

  13.  The PPG should be the ideal vehicle for government to express its strong advice that every local planning authority should produce "parks and open spaces strategy". Such a strategy needs to be based on a consistent typology, good data and needs-assessment.

  14.  The PPG does not recognise what the Select Committee and the DTLR Taskforce refer to as "the information deficit" when it comes to parks—their numbers, their condition, their funding, their use and the wishes of the local community. This must be flagged up, and the collection and analysis of reliable data must be a priority for planning authorities.


  15.  Needs-assessment appears to be heavily skewed towards sports provision: Sport England, referred to in paragraph 17, does not address needs assessment for passive recreation and informal play, let alone for the other benefits of well-designed parks and gardens, except for the narrow band of sports-users. We welcome paragraph 22 on assessing informal recreational facilities (here facilities seems to mean open space as well as buildings) but it is isolated in a section (paragraphs 17-23) dominated by the well-established methodologies for assessing sports and playing fields provision. The PPG needs at least to outline a methodology for needs-assessment and evaluation for passive recreation of the kind enjoyed by park-users.

  16.  The desirability of providing good, well-designed new parks and open spaces is flagged up in PPG 3, and in the Urban White Paper. The most practical mechanism for this is afforded by planning obligations and s. 106 agreements. It is essential that there is an end to tokenism—fragmented or soul-less areas of mown grass which makes no contribution to amenity, wildlife, or landscape. The PPG should emphasise the message in PPG 3 that agreements must emphasise quality over quantity, and also—as wisely pointed out in paragraph 62—ensure resources for proper maintenance. Paragraph 56 refers to By Design, but that does not give examples of good designs for parks, gardens and open spaces, only for features within them.

  17.  We would also urge the inquiry to consider that provision of new open space is less of an issue than the good management of existing. Advice on this subject is woefully lacking in the draft PPG, and while management may be the responsibility of a separate local authority department from planning, it is essential that planners understand management issues; for example, in drafting s. 106 agreements that secure new open space, or—in the wider sense—in delivering the kind of green space which will contribute to the planning objectives of the urban renaissance.

  18.  Despite its familiarity to planners, the NPFA six-Acre standard has proved to be an inadequate mechanism for delivering quality open space: it is essentially a quantative measure. While the PPG acknowledges the need for quality, it does not tackle the future provision of national standards. We believe that this is a serious omission.


  19.  From the above, it should be clear that we think the PPG is largely unsuccessful in this. The subject of open space appears to have been "bolted on" to the existing sport and recreation guidance. It is neither afforded enough guidance in its own right nor explored in relation to sport and recreation.

  20.  We believe that as it stands, the PPG would not only fail to give strategic guidance on open space; it would have a negative impact as a result of its confused wording.


  21.  We have been anticipating this draft with great interest in the light of the Urban White Paper. That document promised that the revised PPG would "give local planning authorities a clearer framework for assessing their needs for open spaces, making good deficiencies and protecting what is valued, and ensuring that everyone has adequate access to open space". The PPG would also, the White Paper went on, "aim to ensure that existing spaces are protected from development where appropriate and that new open spaces are well designed". In the light of these expectations, we must express our disappointment at the draft, and urge that significant changes are needed if it is (a) to deliver what the UWP promised and (b) not to have a negative impact on strategic planning for open space.

  22.  The PPG does not contribute to the aspirations set out in the UWP. Those aspirations are being worked through and developed by the Urban Parks and Green Space Taskforce set up in the wake of the publication of the Urban White Paper, and it makes little sense to publish a document purporting to join up with the Urban White Paper in advance of the Taskforce report. The evidently hurried nature of the PPGs treatment of open space suggests that it is intended to fulfil the promises in the UWP, but it patently fails to do so.


  23.  In conclusion, we are uncertain whether to advise that the PPG needs fundamental revisions, or that open space merits its own separate PPG. This will clearly be a matter for the Committee, but on balance, we would favour the former option. Securing an entirely new PPG would we guess be a lengthy matter. However, the flaws in the existing draft should not be underestimated and if the eventual version of the PPG is to be useful, then serious work is needed. We would certainly advise that the DTLR Taskforce report be used to inform the drafting, and in particular we must highlight the need for:

    —  a proper terminology and typology;

    —  guidance on national standards;

    —  guidance on strategic planning for open space;

    —  guidance on understanding management.

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