Memorandum by English Nature (PPG 13)|
English Nature welcomes the decision by the
new Urban Affairs Sub-committee to inquire into the draft PPG
17, and the opportunity to provide comments. The particular focus
of the Inquiry on the potential contribution of the PPG in providing
guidance on open spaces in the context of the urban renaissance
is to be welcomed. We provided a submission to the recent consultation
on the draft PPG 17, document NPT/03/02/241, dated 15 June 2001.
Although we welcomed much of what the draft
PPG was proposing, we raised a number of issues which we felt
that it was weak on. In our view, these still need to be addressed.
In particular, these include:
an apparent focus on formal, as opposed
to informal, recreation;
insufficient account being taken
of the Countryside and Rights of Way Act 2000;
a lack of definitions in respect
a lack of clarity of objectives;
little recognition of the contribution
that open spaces make towards biodiversity conservation and environmental
function (eg flood control, pollution amelioration);
little recognition that sport and
recreation can have adverse impacts on biodiversity and other
natural features; and
lack of guidance as to the mechanisms
by which new open space can be provided.
In addition, English Nature recommends:
That a more holistic view is required
within the PPG to reflect the multi-functional role that green
open spaces provide in our towns and cities.
That over-arching and integrated
spatial and qualitative standards for open spaces are developed,
that reflect the differing functions that they perform.
That the guidance gives due consideration
of the role that brownfields can play in open space provision.
That consideration is given for the
preparation of a separate PPG on open space.
That Community Strategies, through
Local Strategic Partnerships, act as a framework by which recreational
needs and open space requirements can be identified.
That publication of the guidance
awaits the recommendations of the Government's Urban Green Spaces
1.1 English Nature is the statutory body
that champions the conservation and enhancement of the wildlife
and natural features of England. We work for wildlife in partnership
with others by:
agencies, local authorities, interest groups, business, communities,
individuals on nature conservation in England;
the special nature conservation sites in England;
enablinghelping others to
manage land for nature conservation, through grants, projects
and information; and
enthusingand advocating nature
conservation for all and biodiversity as a key test of sustainable
1.2 We have statutory duties for nationally
and internationally important nature conservation sites, including
Sites of Special Scientific Interest (SSSIs), the most important
of which are managed as National Nature Reserves (NNRs); Special
Areas of Conservation (SACs); and Special Protection Areas (SPAs).
1.3 Through the Joint Nature Conservation
Committee, English Nature works with sister organisations in Scotland,
Wales and Northern Ireland to advise Government on UK and international
nature conservation issues.
1.4 The Committee has asked for a number
of points to be addressed; our comments on these are dealt with
2. GENERAL COMMENTS
2.1 English Nature welcomes the decision
by the Urban Affairs Sub-committee to inquire into the draft PPG
17, particularly in light of a number of concerns we raised in
our submission to the DETR consultation earlier this year,
and the commitments made by Government to provide quality open
spaces in our towns and cities.
2.2 We therefore welcome the emphasis on
urban regeneration in this Inquiry in respect of the protection
and provision of open spaces as an integral element of the urban
renaissance. These are vital not only for recreational needs,
both informal and formal, but also in the contribution they make
to environmental functions, and bringing people closer into contact
with nature, which we believe is an essential part of the quality
of life. We believe that a more holistic view is necessary within
the PPG to reflect the multi-functional role that green open spaces
provide in our towns and cities.
2.3 The broader scope of that draft guidance,
such as the references to biodiversity and the contribution of
open space and recreation to sustainability, were especially positive
moves and to be welcomed. However, we are concerned that the guidance
provided little clarity, especially in respect of standards of
open space provision, nor did it take account of the new Countryside
and Rights of Way Act 2000. This is especially important in light
of the fact that much open space is used informally, both in cities
and the wider countrysidean issue we felt was not given
significant consideration in the draft.
2.4 The draft guidance was published for
consultation after the work of the Government's Urban Green Spaces
Task Force began in February 2001. We suggest that the PPG should
take account of the recommendations made by the Task Force, due
in March 2002, and publication should be delayed until after these
have been considered by Government.
3. DETAILED COMMENTS
3.1 Contribution to strategic planning for
sport, open space and recreation
3.1.1 We remain to be convinced that the
guidance as it stands fulfils this role. This is partly, we believe,
due to insufficient clarity of definitions in respect of open
spaces, and the potential conflicts between formal recreational
uses and the other functions that open spaces support. The guidance
needs to have a clearer focus on the types of land and recreation
which it purports to cover and to define the scope of sport, recreation
and open space. Provision for sport and formal recreation includes
that of built facilities, and does not necessarily relate directly
to open space. In addition, open space performs a wider roleboth
in towns and cities, and the wider countrysidethan simply
that of recreation.
3.1.2 The guidance, crucially, fails to
link to the obligations under the Countryside and Rights of Way
(CROW) Act 2000, in particular the duty on highway and National
Park authorities to set up Local Access Forums under Part V to
advise on the improvements of public access to land for the purposes
of open-air recreation. The responsibility of local authorities
to prepare rights of way improvement plans under Part II is also
relevant. In addition, there is no link to Areas of Outstanding
Natural Beauty (AONBs) and the requirement for all authorities
to prepare AONB Management Plans as a statutory duty under the
Act. Clearer links with this new legislation are required.
3.1.3 The guidance fails to offer a mechanism
by which local authorities can assess the wider recreational needs
of the community. We would suggest that the new Community Strategies
developed through Local Strategic Partnerships, as required by
the Local Government Act 2000, can act as a framework by which
recreational needs can be identified.
3.1.4 Whilst we recognise that Regional
Planning Guidance should promote regionally important recreational
and open space assets in both urban areas and the wider countryside,
the guidance places too much emphasis on facilities for formal
recreation. Many aspects of the open spaces which may be highly
valued and attract large numbers of users do not require sophisticated
facilities; these appear to fit uncertainly and uncomfortably
within the split between Regional, Structure and Local Plans.
We recommend clear reference to Local Biodiversity Action Plans
and Community Strategies which have direct links to open space
provision, management and use.
3.1.5 Certain recreational activities require
particular features of the landscape which may be present in only
a few places within a region. It must be recognised that those
who wish to participate in these more specialised activities must
be expected to travel further to satisfy their needs. Local examples
of important habitats or features should not be put under undue
pressure simply because they are the only facilities theoretically
available locally to a specialised user group. We would wish to
see the guidance ensure that the amenity value of such features
should not be promoted at the expense of their ecological, geological
or landscape interest where this is significant.
3.2 The contribution of the PPG to the provision
of high quality new open space and sports opportunities
3.2.1 We welcome the inclusion of biodiversity
conservation within the guidance as one of the roles of open spaces,
both in urban and rural areas. However, it is unclear what mechanism
is envisaged to provide new spaces to fulfil this role. There
is also the issue of the definition of "high quality",
which would differ according to the function of any particular
3.2.2 We would hope that the guidance would
make specific reference to the evaluation and identity of non-statutory
wildlife and geological sites as part of local planning authorities'
commitments to the conservation of their natural heritage (which
is by and large directly linked to the provision of open space),
as outlined in PPG 9.
3.2.3 In addition, the declaration of Local
Nature Reserves under Section 21 of the National Parks and Access
to the Countryside Act 1949, provides an opportunity for local
planning authorities to make special provision for sites whereby
the links between the conservation of natural features can be
linked to informal recreation and education. English Nature's
current Wildspace! grant scheme aims to encourage the further
declaration of LNRs across England, especially in areas of high
socio-environmental deprivation. We support the other New Opportunities
Fund grant schemes with similar aims to encourage the establishment
of new open spaces, such as the Countryside Agency's Doorstep
Greens and BTCV's People's Places (of which we are a partner).
3.2.4 We strongly support the draft's emphasis
on the provision of access to informal recreational space close
to where people live. We would like to see, within the guidance,
the promotion of English Nature's standards and targets for accessible
natural greenspace [ANGSt] as an aspirational framework for local
planning authorities to work towards.
We are currently developing a tool-kit of ANGSt that takes account
of the Urban White Paper's commitment to the provision of quality
open space, and aims to assist local planning authorities in the
means to meet the standards across a range of urban forms, from
market town to large metropolis, from outer suburbia to inner
3.2.5 There needs to be clearer links to
open spaces serving multiple functions which include nature conservation,
such as the role of Local Nature Reserves, village, Millennium
and Doorstep Greens, and the potential of local authorities to
enter into management agreements under section 39 of the Wildlife
and Countryside Act 1981 which now extends to the urban environment
following an amendment introduced under the CROW Act 2000. It
is important for local communities to take responsibility and
"ownership" for local sites where possible, where they
can cherish, protect and manage these.
3.3 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
3.3.1 This is, we believe, the weakest aspect
of the guidance as it stands. It is apparent that the issues of
open space protection and provision have been "shoe-horned"
into those of sport and recreation. At present the wider benefits
of open space have not been given sufficient weight, nor the potential
conflicts between these and sport and formal recreation.
3.3.2 Indeed, there is much to recommend
that separate planning guidance should be produced for open space
per se. This could then consider the wider functions it can perform
in respect of landscape, biodiversity conservation, environmental
function (eg flood soakaways, pollution amelioration), informal
and formal recreation, heritage conservation, and tourism. For
example, visitors to the open spaces which involve few facilities
considerably outnumber those making use of formal sports or recreational
facilities; this is not given adequate consideration in the draft.
3.4 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
3.4.1 English Nature fully supports in principle
the need for an urban renaissance, and we strongly support the
recognition of the role of open green space in contributing to
this. However, open space is land-hungry and the PPG doesn't explain
how the provision of open space within urban areas can be reconciled
with higher density compact cities which the Government's Urban
White Paper encourages. There is a need to set aspirational yet
achievable standards for open space provisionboth spatial
and qualitativethat not only meet the recreational needs
of local people, but also fulfil wider environmental objectives.
3.4.2 There are a number of open space standards
that are promoted and used by local authorities, including English
Nature's ANGSt, which are spatial and/or qualitative. This variety
reflects the different functions of open spaces, but can lead
to potentially conflicting objectives and standards. There is
as yet little attempt to link or integrate them. We suggest that
there is a clear need to review the variety of standards used
and provide guidance for a more integrated and holistic approach
to national open space standards.
3.4.3 We feel that greater emphasis should
be put on the contribution which natural greenspace and biodiversity
makes to people's quality of life, in towns and cities as much
as the countryside. There is ample evidence to show that the provision
of natural greenspace and wildlife habitats in urban areas is
as important as the more formal landscapes required for certain
types of recreation or sport.
These need not be confined to particular sites (eg nature reserves),
but integrated with the on-going management and usage of an open
space which fulfils a number of functions. Although we recognise
that there are sometimes conflicts between biodiversity conservation
and recreational interests, there is plenty of practical guidance
and many good examples that demonstrate that the two can often
be successfully combined.
3.4.4 The Urban White Paper plays great
emphasis on the need to focus new development on brownfield sites.
In many urban areas, brownfields are often the only open spaces
available. In addition, many support a comparatively rich biodiversity,
and especially that of a character that reflects the cosmopolitan
nature of our towns and cities. We recommend that the guidance
gives due consideration of the role that brownfields can play
in open space provision, and that new development be sympathetic
both to the needs of people's recreational requirements and also
3.4.5 Recognition needs to be given to the
fact that many urban open spaces are protected through a range
of designations such as Conservation Areas, Metropolitan Open
Land, Local Open Space, Historic Parks or Gardens, Sites of Special
Scientific Interest, Local Nature Reserves, Green Corridors, or
wildlife sites, etc. This amplifies the multi-functional role
of open spaces in towns and cities which we believe is not adequately
reflected in the guidance. English Nature's research into multi-functional
green networks and the role of wildlife sites in acting as nodes
of excellence can provide a basis for open space planning in urban
3.4.6 We support the recognition that open
spaces can provide conduits for environmentally sustainable transport
usage, especially in the context of urban regeneration. However,
this should not be at the expense of any adverse impacts on biodiversity
and natural features. New cycle routes and footpaths, for example,
must be progressed in the context of Local Biodiversity Action
Plans, although there may be opportunities to enhance biodiversity
through sensitive design and the creation of new features.
3.4.7 There is also a need to emphasise
the value of protecting landscape, amenity and strategic views
where these form part of the appreciation of visiting open space,
even where that visual amenity falls outside the sites actually
3.5 The contribution of the PPG to achieving
the Government's aspirations on urban parks and play provisions
as set out in the Urban White Paper.
3.5.1 It is not clear how the guidance can
assist the Government's aspirations on urban parks and play-spaces,
given that the emphasis is largely on sport and formal recreation.
Whilst we acknowledge the good intentions to address the aspects
of park provision within the guidance, the lack of clarity and
the failure to prescribe standards leaves the draft PPG wanting
in this respect.
3.5.2 High quality parks and play-spaces
require significant investment, both for capital improvements
and restoration, and on-going maintenance and promotion. We therefore
welcome the establishment of the Urban Green Spaces Task Force
in light of the Environment Sub-committee's Inquiry into Town
and Country Parks, and the recent Urban White Paper. However,
we would recommend that publication of the PPG be delayed until
the Task Force has submitted its recommendations to Government
in March 2002.
3.5.3 Good management of urban green spaces
is crucial and we would recommend the need for minimum standards
to be achieved by local authorities, whether through the Green
Flag Parks Award Scheme, the Eco-Management Audit Scheme, or similar
certification schemes. Recent reports highlight the deficit of
skills in parks management, and we would hope that if schemes
were introduced to address this, that biodiversity conservation
would be an element of this.
3.5.4 The role of local communities in the
management of their local open spaces or indeed formal facilities
is also increasingly important and deserves greater recognition.
Many "Friends of" groups have emerged in recent years
and are now working successfully with local authorities and other
partners to improve the quality of many parks and open spaces.
We would recommend the guidance places emphasis on the emerging
Community Strategies as a means of involving local people in the
stewardship and decision-making process in respect of their open
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