Communities and Local Government CommitteeWritten evidence from GreenSpace
GreenSpace is a national charity solely dedicated to the conservation and improvement of public parks and all other forms of publicly accessible green space. We represent professionals working in the sector and community groups that are actively working to improve green space. Around half the local authority parks and green space teams in England are members of GreenSpace and we maintain a network of around 1,000 community based voluntary groups. We provide networking opportunities, support benchmarking, undertake area and national based research, dissemination of good practice through advice, conferences, training and publications and deliver campaigns and advocacy.
Summary
Improving on the work started in PPG17 to define and recognise the value of different types of green space including defining the terms “community green space” and “local green space”.
Use the opportunity of new definitions to provide greater enhancement and protection from development to different types of green spaces.
Provide a clear translation of the definition of sustainable development to ensure that the principles can be more effectively applied by planning authorities, developers and communities.
Do not rely on local interpretation of the framework to ensure that green infrastructure is enhanced and protected
Commit to a balanced strategic supply of green space as not all green space is beyond the scope of development.
Ensure that neighbourhood panels are supported in the to make informed decisions.
Use the community infrastructure levy to place greater emphasis on a duty upon developers to ensure that the increased burden that they place on surrounding infrastructure is addressed through their contributions, thus enhancing developer’s commitment to big society and localism.
Does the NPPF give sufficient guidance to local planning authorities, the Planning Inspectorate and others, including investors and developers, while at the same time giving local communities sufficient power over planning decisions?
No. The Minister suggests that the replacement of over 1,000 pages of national policy and guidance with around 50 pages should be a cause for celebration. We suggest that this is indicative of the dumbing down and over simplification of the complex issues involved in relation to an effective planning policy framework. As an example of this, we were extensively involved in the development of PPG17 Planning for Open Space, Sport and Recreation. Whilst PPG17 was useful, within our sector it was felt that it still didn’t sufficiently recognise the value of community green spaces and green infrastructure, and certainly didn’t offer sufficient protection from potential development. What it did provide was a set of good practice principles, around which a community, desperate to safeguard its right to access good quality, green space could develop an effective defence.
Within the new Draft Planning Policy Framework there is nothing in terms of open space provision and open space protection that compares to PPG17. Given that PPG 17 was already ineffectual, this can only mean that open space provision has even less protection. In saying this, we need to highlight that we do not believe that all public green space is sacred and beyond the scope of development. We are instead committed to a balanced strategic supply ensuring that all communities have good access to a diversity of high quality green spaces and that the totality of the local green infrastructure supports and provides vibrant and sustainable ecosystem services as well as meeting the social, recreational and health needs of communities.
Part of the problem with the draft Framework, and its justification for the abandonment of the raft of specific and detailed guiding principles, is its reliance on local interpretation. Where communities and their local authorities are equally committed to protecting and enhancing green infrastructure, the new Framework offers the scope for appropriate interpretation. Where a local council, with or without the support of the local community, cares less about environmental quality than economic growth and local business, it can choose to apply a polar opposite interpretation of the framework and lay waste its green infrastructure in a comparatively unfettered manner. We note that local planning authorities are now required to prepare a Strategic Housing Market Assessment, but there is no longer a requirement to produce an Open Space Strategy or Regional Spatial Strategy.
The protection and enhancement of green infrastructure, ecosystem services and biodiversity is too important to be dependent on the whims of local interpretation. Its role in climate change mitigation and adaptation alone dictates that more is needed than is offered in the draft framework. Add to this its contribution to public health and wellbeing, community cohesion, cultural heritage and sense of place and it soon becomes obvious that the 50 or so pages represent a potential threat to sustainable environmental management.
We welcome opportunities for increased community involvement and decision making influence in the planning process. In general parks and green spaces are massively appreciated by the communities they serve with most communities inclined towards their protection rather than their loss. However, we are reminded of the adage “you don’t know what you don’t know”, and in the absence of good guiding principles and examples of good practice, supported by detailed and specific planning guidance, there is a danger that communities will come to regret many of their decisions in relation to development approvals they are a party to: if they haven’t seen what has been achieved elsewhere through different approaches to that which is being locally championed then how can they make a truly informed judgement? Well-meaning but ill-informed decisions that lead to the loss of elements of the green infrastructure or heritage assets are likely to be irreversible and may well erode the quality of life of individuals living within these communities, both now and across generations to come. We have major concerns about the level of support that will be available to Neighbourhood Panels to ensure that they are representative and that they have access to the information and advice they will need in order to make informed decisions and make a genuine and meaningful contribution to the decision making process.
The Community Infrastructure Levy (CIL) is presented as supporting and incentivising development rather than placing the emphasis on a duty upon developers to ensure that the increased burden that they place on the surrounding infrastructure is addressed through their contribution. The burdens created by new development often extend well beyond the immediate confines of the neighbourhood in which the development takes place. The proposed use of CIL appears to be more about “oiling the wheels” to achieve planning consent than meeting genuine strategic needs, effectively bribing communities with financial enticements to approve proposals that may cause long term harm to communities far in excess of the relatively small financial reward they receive. Proposals should first be assessed for sustainability, then for need, then for appropriateness and only when these tests have been positively met, should there be a calculation of an appropriate level and use of the CIL; is it good? Is it needed? Is it appropriate? What costs need to be met?
Is the definition of “sustainable development” contained in the document appropriate; and is the presumption in favour of sustainable development a balanced and workable approach?
No. The statement “sustainable development means development that meets the needs of the present without compromising the ability of future generations to meet their own needs” is a wholly insufficient descriptor in planning and development terms. Clear and consistent guidance needs to be developed to translate the tenets of sustainability into practical terms that can be applied to planning and development processes. The definition is too vague to be applied accurately by planning authorities, developers and communities.
This issue is at the heart of most of the concerns about the draft. If the Government were to adopt the established and recognised definition of sustainable development, that which is provided by the World Commission on Environment and Development, many who currently oppose the framework would find themselves instead supportive and even excited by its potential. As it is, the Government’s use of the term “sustainable development” is seen as a cheap trick; a smoke screen for allowing business and economic development to take unchallenged preference over any concerns about the environment, historic and cultural heritage and community cohesion and distinctive identity. Economic prosperity cannot exist in a vacuum; it is in itself only sustainable within the context of material, societal and environmental sustainability.
Are the “core planning principles” clearly and appropriately expressed?
With such an insufficient commitment to and definition of sustainable development, at present the core planning principles can be interpreted as; “if there’s a market demand and therefore money to be made, development proposals should automatically be approved”. The notion that Local Plans should set out a “positive” long term vision for an area, reads as if the term positive only refers to economically growing.
The statement “decision-takers at every level should assume that the default answer to development proposals is ‘yes’ is simply dangerous”. A better position would be to say that “provided a proposal can demonstrate and meet the tests of sustainability (in its true sense) and meets a recognised need within the community, then the default answer should be ‘yes’”.
In the fifth bullet point provided, there is a disconnection between enhancing environmental and heritage assets and the issue of reducing pollution; why are these two issues connected in this clumsy and inappropriate manner? The statement “where practical and consistent with other objectives, allocations of land for development should prefer land of lesser environmental value” should read “wherever possible, allocations of land for development should prefer land of lesser environmental value” and should be established as a presumption. The term “lesser environmental value” will require careful definition based on sound evidence, as some may argue that even contaminated land has a high environmental value as that land can be restored, even after years of heavy industrial use.
If the statement provided in the sixth bullet point “recognising that some open land can perform many functions” refers to green space then it should recognise that all green space (to greater or lesser degrees) performs many functions. There should be a stronger statement about the multiplicity of functions provided by green space and green infrastructure in relation to ecosystem services and recreational and social opportunities.
The commitment to the re-use of resources and the use of renewable resources provided by the seventh bullet point just isn’t strong enough as a guiding principle. The technology, tools, materials and knowledge exists to ensure that all future approaches to development are much more sustainable and can mitigate rather than compound climate change issues. Development can be carbon neutral, but requires a genuine commitment within the planning policy framework. How long will we continue to ignore the issues of environmental sustainability?
The ninth bullet point refers to supporting local strategies to improve health and wellbeing for all but fails to highlight that this should include strategies for protecting and enhancing access to quality green spaces and managing green infrastructure.
Is the relationship between the NPPF and other national statements of planning-related policy sufficiently clear? Does the NPPF serve to integrate national planning policy across Government Departments?
No. In relation to the significance of green spaces, as highlighted in the recent Natural Environment White Paper (NEWP) and in the Marmot Review which informed the Health White Paper (Healthy Lives Health People) this draft framework seems completely unconnected; worse than this, at times it seems completely conflicting with these two documents. The NEWP highlights the massive economic value of ecosystem services, warning that economic growth cannot be sustainable unless there is effective stewardship of the environment. The Health White Paper highlights the vital role of green space in addressing health inequalities between rich and poor communities. The planning policy framework completely fails to recognise these issues and the imperative to properly consider these issues within planning based decision-making frameworks.
There seems to be a lack of joined up thinking and cross-departmental working by government in relation to other policy developments, particularly around the Localism Bill. The Bill makes provision for local neighbourhood planning and abolition of regional spatial strategies, whilst attempting to make it easier for communities to challenge the way services are run and buy and develop their own services. Provision for these “localism” activities will need to be more comprehensively detailed in the NPPF. Similarly, Defra’s proposal’s to charge a fee for village green registration applications by communities seems to conflict with the principles of the localism bill. Conversely placing greater duties on developers to make contributions that mitigate the burden placed on infrastructure by their development may support the big society agenda.
Does the NPPF, together with the “duty to cooperate”, provide a sufficient basis for larger-than-local strategic planning?
No. From the perspective of our organisation, our entire sector and indeed Defra, sustainable management of green infrastructure demands that strategic management approaches operate at a landscape level and necessitate cross boundary working beyond county and neighbouring authority level.
There is no connection with the Local Nature Partnerships, Nature Improvement Areas and Green Infrastructure Partnerships outlined in NEWP which will be essential if the planning framework is to support cross-boundary green infrastructure initiatives in the future.
Are the policies contained in the NPPF sufficiently evidence-based?
GreenSpace would like to work with government to assist to ensure that the new NPPF is based on sound evidence from the green space sector. The NPPF makes some commitment towards the delivery of open space, sports and recreational facilities and draws on the current approach of assessing needs and opportunities at a local level to assess provision. In addition, the NPPF recognises the contribution that open space makes to health and well-being, but there are many other cross-cutting agendas that high quality green infrastructure can support, such as the economy, climate change, social cohesion. GreenSpace has produced “Blue Sky Green Space” as evidence that supports those contributions, and would like to see the value of all types of green spaces recognised within the NPPF.
Accurate measures and indicators for the true impact of the loss of green space in favour of development will be essential components to enable the effective delivery of sustainable new developments. The Green Flag Award is at present the only formal quality measure of green space, however since this was dismissed by the previous administration as a national quality indicator, there now lacks accountability of quality green space provision at local government level.
The new “open space assessments” proposed in the NPPF should follow the latest socio-economic thinking around cost benefit analysis, and link to asset management strategies. Nevertheless, the loss of the requirement for authorities to provide broader green space strategies, that aim to assess access, quality and provision of green spaces and puts local provision in a wider context, may create a serious hierarchical gap in the planning and delivery structure of new developments versus broader open space provision. Parks and green space assets should not be managed on an individual case-by-case basis but strategically, and in a wider green infrastructure context if our society is to benefit from the rewards these ecosystem services provide.
There is a general lack of clarity around terminology used in the NPPF “community green spaces” and “local green spaces”, and green spaces versus open spaces, aren’t presented this way within the PPG17. PPG17 offers a reasonable definition of other types of green space such as outdoor sports facilities, cemeteries and allotments. There is a real opportunity for the NPPF to improve the classification of habitats and definitions of PPG17s “Parks & Gardens” which at present is vague, to be usefully applied within the local planning process. Parks for Life, the international parks alliance of which GreenSpace is partner, is working towards developing a new international classification system which may help to support the development of new definitions in the NPPF.
September 2011