Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by English Heritage (PPG 06)


  1.  English Heritage welcomes the opportunity to submit a memorandum to the Sub-Committee on planning for sport, open space and recreation. Because of our statutory remit, our comments are necessarily restricted to England.

  2.  English Heritage is the Government's lead body for the historic environment in England. Its tasks include:

    —  advising national and local government on all aspects of the historic environment;

    —  advancing understanding of the historic environment through survey and research;

    —  giving £38 million a year in grants to historic buildings, sites, parks and gardens;

    —  managing 409 historic properties (including parks and gardens) on behalf of the state;

    —  running the National Monuments Record;

    —  through our educational work, increasing public understanding of the historic environment.

  3.  English Heritage submitted comments on the public consultation draft version of PPG 17, and together with the Countryside Agency, English Nature and Sport England raised common concerns in a joint letter to Lord Falconer.

  4.  PPG 17 was originally published in 1991, and revised guidance is long overdue. In its comments, English Heritage therefore welcomed the decision to update it, but felt that the draft was premature, as the Ministerial Urban Green Spaces Task Force had not yet completed its work. We were looking to a revised PPG to be one of the keys to the urban renaissance promoted by the Urban White Paper[3]. One of our main concerns was the lack of recognition of the historic and cultural importance of parks and other open spaces, and of their critical role in neighbourhood renewal and in the creation of "liveable" cities.

  5.  Although responsible for very different sectors, the four agencies all felt that the draft represented a missed opportunity.


  6.  Squares, walks, commons and open spaces used for many different kinds of recreation were a feature of England's pre-industrial towns and cities, but were rarely provided in the rapidly growing urban centres of the late eighteenth and early nineteenth centuries. In 1833, the report of Select Committee on Public Walks recognised the need to provide public walks and open spaces for "comfort, health and content", which helped to spur the municipal park movement during the middle years of the nineteenth century[4]. The same concerns are still relevant, and public open space remains critical to the quality of life in urban areas.

  7.  The English townscape is characterised by the number and diversity of its public open spaces. Not all are owned and managed by local authorities, and the planning system has an important role to play in ensuring their survival and protecting and enhancing their character and value. Other incidental open spaces, including private gardens, also play an important role by providing "green lungs" and creating a sense of place.

  8.  As long ago as 1902, an Act was passed to protect the landscape and views from Richmond Hill in London for the benefit of the public. Currently, the Register of Parks and Gardens of Special Historic Interest in England[5] includes over 1,400 sites, including nationally important examples public and country parks, squares, cemeteries and allotments. It is nevertheless important to remember that open spaces often have historic character and value even if they are not formally designated as conservation areas or registered landscapes. There is no part of England that human beings have not helped to shape and transform, and the environment as a whole has a historical dimension that needs to be recognised, understood and evaluated.

  9.  England's public parks used to be symbols of civic pride. Their success, and the quality of their design, is demonstrated by the extent to which that they are still valued by their users, even where they are no longer adequately maintained.

  10.  A joint report published in 1993 by the Garden History Society and the Victorian Society[6] highlighted the need for action to rescue public parks from decline. The quality of what is at risk is demonstrated by English Heritage's annual Buildings at Risk Register, which shows that 34 Grade I and II* listed structures are currently at risk in registered local authority parks. Since Grade I and II* listing and registration are both of necessity highly selective, this is a worryingly high figure, the tip of an iceberg. Following the former Environment Select Committee's recommendations on Town and Country Parks[7], English Heritage joined DTLR, the Heritage Lottery Fund and the Countryside Agency to commission a survey of local authority owned parks to quantify the problem. The report[8] shows that the loss of features and facilities traditionally associated with historic parks like fountains, cafés and toilets is widespread, and that this decline looks set to continue. Sport and recreation facilities such as boating, paddling pools, tennis courts, golf and putting are also disappearing. In all, 39 per cent of parks and open spaces are in decline.


  11.  District-wide sport and recreation strategies were recommended in the 1991 PPG, but, 10 years later, the condition of public parks and open spaces suggests that the aspiration to bring together land-use planning and other local authority strategies has not yet been achieved. English Heritage's recent guidance on streetscape design, Streets for All [9], highlighted how poor management can undermine character, and argued the need for integrated townscape management. A comprehensive vision is essential, and the new version of the PPG needs to help local authorities achieve this at neighbourhood level.

  12.  We would not advocate free-standing strategic plans for open space, since local authorities are already suffering from strategic overload, but strategic thinking about open space should be an integral part of Local Cultural Strategies and Community Strategies and in planning for neighbourhood renewal.

  13.  The Urban Green Spaces Task Force is developing definitions of different types of green space and their related community values. The PPG could usefully be complemented by good practice guides embodying quality standards (tying in benchmarking and Green Flag awards) for the whole range of public open space, including, where appropriate, horticulture. This would mirror other design guides linked to PPGs, such as DETR's By Design[10] and PPG 13 Transport: a guide to better practice.


  14.  Sustainable high-quality open space requires effective management and maintenance as well as good, sensitive, design, responsive to the needs and character of the area. It is therefore important that any design guidelines or good practice guides linked to the PPG emphasise the importance of taking future maintenance costs into account.

  15.  This does not necessarily mean abandoning traditional horticulture. For example, Haringey Borough Council used carpet bedding to publicise the 1997 European Year Against Racism, with photographs of the planting being used in a wider publicity campaign, while the popularity of gardens like those of Hampton Court suggests that expenditure on horticulture can be fully justified in terms of its contribution to the quality of life. Quality open space is most needed in poor high-density neighbourhoods, where local authorities need more support.


  16.  Public open space is precious and needs to be protected. The draft PPG seeks greater protection for playing fields, and a general presumption against development should now be firmly established. However, without thoroughly understanding the role and function of a particular open space (which may well evolve and shift over time) it will not be possible to say whether it could be released for development, or to determine the type, size or location of any new sites that might be required in mitigation. Not all open space is substitutable: there is an acute shortage of open space in some neighbourhoods, and some sites, including many historic public parks, will be irreplaceable.

  17.  A presumption against development should also ensure that sites are not at risk of being eroded, for example by road improvements. Public parks in particular are often surrounded by land of prime development value, which can make them an easy option when new public facilities are required. The PPG needs to provide clear guidance on new buildings and structures on these sites to guard against inappropriate or unrelated development. New development in or adjacent to open space needs to take into account its character and potential if it is not to diminish its value. The historical dimension needs to be considered and its significance identified and evaluated whether or not the land is formally designated as a conservation area or registered landscape.

  18.  The PPG could helpfully consider potential conflicts between various protective policies such as sports provision and open land. For example, open-air sport has been regarded as an appropriate use of Green Belt land despite the fact that sophisticated modern facilities may no longer be in the spirit of retaining expansive open and green landscapes.

  19.  The PPG could consider how public open space might benefit more through the use of planning obligations. Local plan policies need to identify how s 106 agreements might be used, not only to provide new green spaces but to improve the management and maintenance of those that already exist. Local authority urban designers need to advise more generally on the provision and design of open spaces in planning applications.


  20.  Dame Jennifer Jenkins summed up the role of public open space in urban renaissance in her comments published on 23 August 2001: "British cities are beginning to realise that their reputations are mirrored in their parks, a lesson most strikingly demonstrated in New York, where the descent of Central Park into a no-go area was a sign of the city's decline, while its restoration signalled the city's revival . . . until neglected spaces in run-down neighbourhoods match well cared-for gardens in prosperous city centres, regeneration will be an empty word".

  21.  The results from the MORI poll commissioned last year for Power of Place[11] (the report to Government led by English Heritage on the future of the historic environment) showed that:

    —  88 per cent of the population thinks that the historic environment is important in creating jobs and boosting the economy;

    —  87 per cent think that it plays an important part in the cultural life of the country;

    —  87 per cent thinks it is right that there should be public funding to preserve it;

    —  85 per cent thinks it is important in promoting regeneration in towns and cities.

  22.  Quality urban green space brings a cascade of economic, social and environmental benefits such as land values,[12] people's health and well being, pleasant routes for pedestrians and others,[13] and biodiversity. The PPG needs to provide useful, focussed guidance on how these benefits can be identified, evaluated and delivered.


  23.  Public parks can be stimulating and safe environments for children to play, but they need to be well managed and maintained. Given the quality of much traditional park design, it will often be sufficient to provide adequate staffing for security purposes and to reinstate traditional features and essential facilities such as toilets rather than provide new infrastructure. The Public Parks Assessment report highlights the loss of children's play features like paddling pools. Successful park management for children would have the effect of creating attractive parks for everyone to enjoy.

  24.  The Urban Green Spaces Task Force's research on the numbers and types of users, patterns of use, groups of users, and non-users and barriers to use will provide useful information for the PPG.


  25.  The key points from this memorandum are:

    —  Liveable cities depend on quality public open space, and good sport and recreation provision.

    —  The planning system has an important role in guiding the provision and management of public open space, but is only one mechanism among many.

    —  A PPG on public open space is welcome, but needs to be fully developed (it would be better titled "public open space, sport and recreation", to distinguish between the land resource and its uses).

    —  Like the Urban Green Spaces Task Force, the PPG needs to take an integrated approach to open space. Open space can serve a wide range of different functions and have multiple values and significance. They all need to be taken into account.

    —  Open space is an important part of the historic environment. Understanding and evaluating its significance is essential.


  26.  We have no objection to this memorandum being made available for public inspection.

September 2001

3   DETR (2000): Our Towns and Cities: the Future. Back

4   See Hazel Conway (1991): People's Parks. Back

5   English Heritage (1998): The Register of Parks and Gardens: an Introduction. Back

6   Garden History Society and the Victorian Society (1993): Public Prospects: Historic Urban Parks under Threat. Back

7   House of Commons Environment, Transport and Regional Affairs Select Committee (October 1999) Twentieth Report: Town and Country Parks. Back

8   DTLR, Heritage Lottery Fund, English Heritage and the Countryside Agency (May 2001): Public Park Assessment. Back

9   English Heritage (2000): Streets for All: a London Streetscape Manual. Back

10   DETR (2000): By Design: Urban Design in the Planning System. Back

11   English Heritage (2000): Power of Place. Back

12   See Mike Luther and Dietwald Gruehn (2001): "Putting a Price on Urban Green Spaces" (Landscape Design September 2001). Back

13   House of Commons Environment, Transport and Regional Affairs Select Committee (June 2001) Eleventh Report: Walking in Towns and Cities. Back

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Prepared 16 October 2001