Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by The Countryside Agency (PPG 19)


  The Countryside Agency is the statutory body working:

    —  to conserve and enhance England's countryside;

    —  to spread social and economic opportunity for the people who live there; and

    —  to help everyone, wherever they live and whatever their background, to enjoy the countryside and share in this priceless national asset.

  We welcome this opportunity to submit a memorandum to the Urban Affairs Sub-Committee Inquiry into the draft planning policy guidance for sport, open space and recreation.

  Although we were pleased to see the revision and updating of this planning policy guidance we feel that the draft must be premature, coming as it does in advance of the report of the work of the Ministerial Urban Green Spaces Task Force. We were also hopeful that the revised PPG would build on the recommendations concerning open space in the Urban and Rural White Papers.


    —  establishing 12 community forests;

    —  establishing Healthy Walking Initiatives;

    —  promoting Greenways;

    —  completing the establishment of 240 Millennium Greens;

    —  managing the creation of 200 Doorstep Greens;

    —  promoting regeneration through environmental action led Area Based Initiatives (REACT);

    —  planning a renaissance of country parks; and

    —  promoting a community led scheme "Pride of Place" to improve the public realm and greenspace.

  The Countryside Agency submitted comments on the public consultation draft version of PPG 17, and together with English Heritage, English Nature and Sport England raised common concerns in a joint letter to Lord Falconer. We understand that the full text of the Agency's consultation response is available to the Sub-Committee for reference so will not be repeated here in full.


    —  the confused and inconsistent definitions of open space reinforce the bias towards organised sport and recreation;

    —  despite the objectives for strong protection of open spaces, the overall message is that unless local planning authorities have conducted detailed assessments which declare particular open spaces of value they can be declared "surplus to requirements" and be regarded as suitable for development. The burden of proof should be the precise opposite. Open space is of value to local communities and there should be a strong presumption against the loss of any open space unless it is proven to be of no value to the community. Once lost, open spaces can rarely be replaced;

    —  far greater emphasis needs to be placed on informal recreation in the countryside with more explicit references to the provision of the Countryside and Rights of Way Act 2000;

    —  the impression given by the document is that only urban dwellers need open spaces or perhaps that rural communities are well provided for. This is often not true, as our Millennium Greens programme has shown. Whilst the emphasis in the countryside will inevitably be on quiet enjoyment, the needs of local communities for organised sport and recreation must not be overlooked;

    —  insufficient weight is given to environmental considerations. Sustainable development means meeting economic, social and environmental objectives together yet the document fails to address issues of landscape character, biodiversity and the historic environment;

    —  the important role of local communities in planning for sports, recreation and open space is underplayed. The need to engage local communities in preparing needs assessments, strategies and development plan policies and in identifying areas of value and enhancement proposals must be explicitly stated and there should also be a reference to the role of town and parish councils;

    —  guidance on assessing need for sport, recreation and open space is insufficiently detailed. Without robust assessments of need for each type of open space, recreation and sport facilities required, appropriate development plan policies and strategies cannot be drafted and needs will remain unmet;

    —  the value of countryside around towns as a significant resource on the doorstep of millions of people is overlooked and insufficient emphasis is placed on the value of community forests and country parks;

    —  there should be greater recognition of the need to improve management and maintenance of urban parks and existing open space, much of which is in very poor condition, and how the planning system can be used to achieve this.


  We have made extensive recommendations for the improvement of the draft PPG 17 in our consultation response. Please refer to that for full details. Our principal recommendations, however, are:

    —  the PPG needs extensive redrafting to address and reflect the concerns above and should be delayed to permit the inclusion of the findings of the Urban Green Spaces Task Force which is due to report in Spring 2002;

    —  the PPG should establish and adhere to consistent terminology throughout and should explicitly mention which of the three elements—Sports, Recreation and Open Space—are covered by each section of the PPG to remove doubt and confusion;

    —  the PPG should be retitled Open Space, Recreation and Sport to reflect the relative importance of each aspect to the population at large;

    —  the PPG should establish a typology of all the different facilities it covers to provide a consistent basis for local analysis;

    —  the typology should form the basis of a national standard for levels of provision of open space, recreation and sport which would provide a marker for local needs assessments.

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

  The Countryside Agency would be pleased to offer its assistance to the Department in developing a document which would meet the Government's objectives and command widespread support.

September 2001

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