Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by The Institute of Leisure and Amenity Management (PPG 07)

  1.  The Institute of Leisure and Amenity Management (ILAM) is very pleased that the House of Commons Urban Affairs Sub-committee has chosen to conduct an inquiry into the draft of Planning Policy Guidance on Sport, Open Space and Recreation (PPG 17). ILAM is grateful for the opportunity to give written evidence to this inquiry. The Institute will be pleased to provide oral evidence to the Committee, if required.

  2.  ILAM is the professional body for managers in the leisure industry. Its membership, of more than 6,000 leisure professionals, covers all sectors including children's play, tourism, parks, open spaces and countryside, sport and recreation, and other cultural provision. Most of ILAM's members are, therefore, involved in the management of sport, open space and recreation, and most of the senior managers in this area are members of the Institute. ILAM's purpose is to promote the better management of leisure resources in order to provide better public access to a wide range of cultural and recreational experiences. This is to enhance the quality of life for individuals and communities. The Institute is an independent registered charity supported mainly by the subscriptions of individual members.

The contribution of the revised PPG to strategic planning for sport, open space and recreation

  3.  The Planning system has an important role to play in ensuring access to leisure of all kinds. It is particularly important in securing recreational land within our urban settlements. It should also ensure that its quality, diversity and accessibility meet all needs. ILAM welcomed the original PPG 17 knowing that in the early 90s there were losses of playing fields to other development which needed the protection of a planning presumption in favour of retaining land for recreation. However, the new draft is 10 years on and the problem of playing field loss has greatly receded. The key issue today is how towns and cities might be made more attractive places to live and work. The key text is the report of the Urban Task Force "Towards an Urban Renaissance" (E & FN Spon 1999).

  4.  Green spaces for recreation is a major land use, accounting for some 14 per cent of the developed land area. However, the new draft appears to severely compromise the opportunity to consider the strategic development of urban greenspace systems as a whole by concentrating on sports provision. If the planning system is mainly about land use then the largest land use should take priority. Most recreational land is not used for organised sport, notwithstanding that the UK appears to have a higher proportion of urban land dedicated to sports pitches than in other countries.

  5.  By presenting such an unbalanced picture the PPG fails to give proper weight to urban ecology and landscape heritage and conservation. Trees hardly get a mention and water space fares little better. The guidance concentrates on "protecting and promoting" what exists rather than the creation of new water bodies, and no guidance on standards for provision of water space appears to be contemplated. Many of the best used and most valuable recreational landscapes are those which combine high quality greenspace and water space.

The extent to which the revised PPG is successful in addressing the newly included subject of open space and reconciling it with sport and recreation

  6.  It isn't true to say that open space is a "newly included subject" for this PPG. A footnote to the original PPG 17 states "This guidance is intended to apply to all types of open space of public value". The new draft is a little less desultory in its treatment of "open space" but the term itself seems mildly pejorative, as if describing land merely waiting for something better to happen, rather than being an essential component of the urban form.

  7.  In our evidence to the earlier House of Commons Environment Sub-committee Inquiry into Town and Country Parks, we proposed a version of the Council of Europe Recommendation No R(86)11 of the Committee of Ministers to Member States on Urban Open Space. We were pleased that the select committee chose to adopt this description in their report. We reproduce it here and commend it to the authors of the PPG.

  8.  "Urban parks and green spaces are an essential part of the urban heritage and infrastructure, being a strong element in the architectural and landscape character of towns and cities, providing a sense of place and engendering civic pride. They are important for enabling social interaction and fostering community development. Public green spaces help to conserve natural systems, including carbon, water and other natural cycles, within the urban environment, supporting ecosystems and providing the contrast of living elements in both designed landscapes and conserved wildlife habitats within our urban settlements. Parks and green spaces are supportive of social and economic objectives and activities. In particular the provision of public parks helps to reduce the inequalities, poor health and social exclusion in deprived areas and reduces the inherent tension between the many social and ethnic groups who form the wider community. Providing for the recreational and leisure needs of a community assists the economic revival of cities, increasing their attractiveness as a place for business investment, to live, work and take our leisure".

The extent to which the revised PPG's treatment of open space will contribute to the urban renaissance, the protection and improvement of open space and improved living environments

  9.  We believe that all the factors contained in our recommended description, based on R(86)11, should be addressed by the planning system and proper guidance given to planning authorities in order to optimise these benefits and purposes. This is essential if urban green spaces are to make a full contribution to providing better and more attractive living environments in towns and cities—the goals of the Urban White Paper, dubbed "Delivering an Urban Renaissance".

  10.  Fine parks and green spaces are a major factor in making our towns and cities more attractive places to live and work, but this much needed shift of emphasis is seriously under-developed in the revised draft. By omitting the term "Open Space" from "Sport and Recreation" almost twice as many times than it is included, the PPG undermines the case for better urban green spaces currently being pursued by the Department of Transport, Local Government and the Regions and its "Urban Green Spaces Task Force". Many of the guidance points given for "sport and recreation" should apply equally to "open space", and thereby to all green spaces, but appear not to in many parts of the consultative draft.

  11.  Critically, paragraph 23, the only paragraph to refer to ascertaining levels of usage to establish value and need, appears to exclude open space from consideration. Whilst the Guidance covers factors to inform plan preparation, the judgements involved must be taken against a background of hard data. Nowhere does it require the planning authority to have determined the actual levels of participation in various recreational activities, locally or nationally. It is this hard data that should be used when setting standards, identifying deficiencies etc. Without this obligation there is a danger that assumptions will be made which don't reflect reality and are open to challenge. Assessing levels of usage for green spaces may be more difficult and resource consuming than for individual sports facilities but in terms of evaluating and planning for land use, just as essential.

  12.  Whilst paragraph 3 makes welcome mention of "The Government's vision for an urban renaissance", "enhance quality of life" and "contribute to the sustainability of urban areas", there is very little in the document to connect these and show how better planning of green spaces for recreation contributes, or what changes and resources are needed to achieve these goals. Again the underlying data, and the degree of commitment exampled by such phrases as "seek to achieve" and, in referring to Health Improvement Programmes, "may also be worthwhile sources" undermines the importance of the links between health and vibrant urban parks for which most of today's greenspace provision has been made via successive Public Health Acts.

  13.  In short, a planning system should look to add benefit. The benefits of high quality urban green spaces spread across the economic, social and environmental but are difficult to quantify. The many memoranda of evidence to the "Town and Country Parks" Inquiry show widespread appreciation of these benefits and their economic impact. However these only apply if quality is upheld. Quality has declined and it is time the planning system was engaged in re-establishing quality as the main criteria.

The contribution of the PPG to achieving the Government's aspirations on urban parks and play provision as set out in the Urban White Paper

  14.  The Institute welcomes the statements in the Urban White Paper which address the provision of parks and play space. There is, at last, a recognition of the decline and an intention to do something about it. This being so, it is regrettable that the Draft PPG 17 was published without reference to the Urban Green Spaces Task Force, set up under the Urban White Paper. As a revision has been waiting for nearly 10 years and the new draft is so backward in its understanding, the rush to publish before the Task Force has considered the role of planning in securing better quality green spaces, is regrettable and pointless.

  15.  The Institute particularly wishes to draw the Sub-committee's attention to the "PARTIAL REGULATORY IMPACT ASSESSMENT FOR REVISION OF PLANNING POLICY GUIDANCE NOTE 17 (PPG 17)" which accompanied the publication of the draft planning guidance. Paragraph 22 of the PPG makes a welcome reference to local authorities "undertaking assessments of the need for informal recreation facilities, including public open space such as parks, children's playgrounds, allotments and footpaths" Yet the accompanying document implies that the effect of the revised PPG is expected to be cost-neutral to local authorities ie "The guidance is about how authorities undertake their existing planning functions, and thus should not impose any further costs".

  16.  This advice should be reconsidered. It takes no account of the serious decline that has taken place in the condition of urban greenspaces in the space of just one generation, and the lack of information on which to base planning policy. Whilst this is mainly due to cuts in local authority maintenance budgets, the perfunctory way in which greenspace planning is presently conducted must take some responsibility. If the situation is to improve, local authorities must devote greater resources to more local research to establish the data needed for better planning and management.

  17.  The Urban White Paper in saying "We must also improve the way we plan and design new parks, play areas and public spaces, and the way we manage and maintain existing ones" seems to recognise a closer relationship between planning and management of open space for public recreation. ILAM believes this is particularly relevant to the sharing of data concerning use and satisfaction with standards of provision.

  18.  By and large, the invitation in the current PPG 17 (1991) to local planning authorities to develop their own standards has been ignored in favour of adaptations of the NPFA "six acre standard" and the GLDP Open Space Hierarchy. Such planning is largely uninformed by surveys of open space usage or assessments of landscape quality. Paragraphs 21 and 22 of the new draft usefully separates NPFA standards from informal open space; this was one of the major misuses of the standard. However, walking distances set by one local authority may differ from those of their neighbour and be challenged by developers. This needs to be guided by research and by the consideration given to this issue by English Nature in their Research Report No 153; "Accessible Natural Greenspace", an important document which, like English Nature itself, is ignored in the consultation document.

  19.  In ILAM's view, a thorough review should first be undertaken of the current state of green spaces and the role of the planning system in their improvement. Such a review would also examine the current methods of assessing needs, including the validity of any standards employed. A parallel study is needed of the impact of the recommendations of the Rogers Report on urban greenspace. None of this appears to have been done before drafting the revision. In Scotland, however, the Scottish Executive has commissioned a study, now published as "Rethinking Open Space" (Kit Campbell Associates 2001). Notwithstanding minor differences between the planning system in Scotland, this new study makes clear the serious flaws in the planning system which the draft revision of PPG 17 appears to perpetuate.

  20.  ILAM believes the revised PPG 17 should recognise the size of the landtake involved in current provision of urban green spaces. This is said to be 120,000 hectares in England and Wales, equivalent to the size of Berkshire. The value of this green estate must also be recognised. The description offered in PPG 17 is inadequate and should be replaced by definitions, firstly of the many types of green spaces which comprise the open space network and, secondly, by a comprehensive description of its purpose such as that offered by ILAM earlier in this memorandum.

  21.  Whilst it is good to have a recognition in paragraph 49 that recreational land may provide useful employment opportunities, the wider benefit of high quality parks and squares to encouraging inward investment, touched on in paragraph 23 is more significant. There are wider economic and environmental benefits than are promoted in this document. For example, the value of trees within urban areas is all but dismissed in paragraph 47, yet they are a most important landscape element with major benefits to air quality and the micro-climate of streets, as well as to sustaining wildlife and enhancing local landscapes.

  22.  In summary, the role of green space in the urban environment, and the role of the planning system in its protection and enhancement, is so under-developed in favour of provision for sport, that the course of action recommended by this Institute is to put the revision of the present PPG 17 on hold, commission research into the practice and effectiveness of current open space planning, commission research into the economic, social and environmental value of the benefits of urban green spaces, and the effect of quality on such value.

  23.  In the meantime, it is sensible not only to await the report of the Urban Affairs Sub-committee but to wait for the Urban Green Spaces Task Force to report to Government, for the NPFA to conclude their current revision of the "Six Acre Standard", and for English Nature to complete its review of its standards for "Accessible Natural Greenspace". With these inputs, including responses to the consultation draft, it should then be possible to produce a redrafted document to be circulated for consultation which would better reflect current need, and make a more positive contribution to the planning of green space, in all its forms, attributes and functions.

September 2001

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