Select Committee on Transport, Local Government and the Regions Memoranda

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 of standards;

    —  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 Task Force.


  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:

    —  advising—Government, other agencies, local authorities, interest groups, business, communities, individuals on nature conservation in England;

    —  regulating—activities affecting the special nature conservation sites in England;

    —  enabling—helping others to manage land for nature conservation, through grants, projects and information; and

    —  enthusing—and advocating nature conservation for all and biodiversity as a key test of sustainable development.

  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 below.


  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[15], 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 countryside—an 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.


3.1  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 role—both in towns and cities, and the wider countryside—than 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 green space.

  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[16]. 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 city core.

  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 environments

  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 provision—both spatial and qualitative—that not only meet the recreational needs of local people, but also fulfil wider environmental objectives[17].

  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[18]. 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 support biodiversity.

  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 areas.[19]

  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 visited.

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 spaces.

15   English Nature, 2001. Revision of planning policy guidance note 17 on sport, open space and recreation: submission by English Nature. NPT/03/02/241. English Nature. Back

16   Harrison, C, and others, 1995. Accessible natural greenspace in towns and cities-a review of appropriate size and distance criteria. English Nature, Peterborough: English Nature Research Reports, No. 153. Back

17   English Nature, 1996. A Space for Nature; nature is good for you. English Nature, Peterborough. 1857162463. Back

18   Rohde, C.L.E., & Kendle, A. D. 1994. Human well-being, natural landscapes and wildlife in urban areas. A review. (English Nature Science Reports, No. 22.). English Nature, Peterborough. Back

19   Barker, G. 1997. A framework for the future: green networks with multiple uses in and around towns and cities. English Nature Research Reports, No. 256, English Nature, Peterborough. Back

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