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Open spaces criteria

Undertaking Local Assessments of Open Space

Brighton and Hove City Council is required under the Government's Planning Policy Guidance 17: Planning for open space, sport and recreation to perform local assessments of Open Space for two purposes:

1. Meeting our open space needs

To ensure that there is adequate provision of accessible, high quality greenspaces, civic spaces and sport and recreation facilities to meet the needs of local communities and visitors.

2. Consulting us on whether an existing open space should be developed

PPG17 also sets out clear policy guidance for authorities when considering planning applications which involve the redevelopment of an existing open space or facility. Diagram 1 summarises the approach to development control set out in PPG17 for such applications and makes clear that authorities will be able to follow its policy requirements only if they have undertaken a comprehensive local assessment.

Section 5.1 Deciding The Scope of the Audit of the Government's Assessing needs and opportunities: a companion guide to PPG17 states that: audits of provision should encompass "all existing open spaces within the local authority's area, irrespective of ownership and the extent of public access.

Questionnaires &/or household surveys on community open space which fail to elicit feedback on the type of open spaces we have in Round Hill will yield incomplete data and will lead to flawed studies, which are not fully compliant with PPG17.

Concern over previous Council surveys
In March 2006, Brighton and Hove City Council asked members of the public to complete an Open Spaces Questionnaire in relation to meeting their needs. While this Questionnaire provided scope for comment by residents living in neighbourhoods where there are parks and recreation grounds, its focus on public open spaces (Round Hill has no parks and recs) did not invite feedback on the privately-owned open spaces, which are the main conservation features of our area.

Residents in Round Hill who have studied the Government's Guidance therefore felt that the Council's 2006 Questionnaire was narrow and selective in its implementation of PPG17. Our concern remains that a Local Government policy which values only accessible open spaces on public land, would give fairly free license to developers proposing to build on Round Hill’s ‘green ribbons’.

The Government's Assessing needs and opportunities: a companion guide to PPG17 makes no attempt to limit itself to accessible open spaces on publicly owned land. One of the guiding principles of PPG17 (2.1 Principles and Concepts) is that the value of open spaces, irrespective of who owns them, depends primarily on two things: “the extent to which they meet clearly identified local needs and the wider benefits they generate for people, wildlife, biodiversity and the wider environment.”

Redevelopment of Open Spaces
PPG17 includes clear guidance on the procedures which should be used for deciding the outcome of planning applications affecting privately-owned open spaces such as back-land between Princes Road and the railway corridor, the ‘green ribbon’ between Richmond & Wakefield Roads and Roundhill Crescent and the attractive segment between Roundhill Crescent and Upper Lewes Road.

Diagram 1 Redevelopment of an Existing Open Space spells out the procedures which should have been applied before (the developer) Carelet’s proposals were even considered by the Planning Applications Sub-committee. Brighton and Hove City Council completely ignored this important strand of Open Spaces Policy. Indeed, the Plans List of 1 Feb 2006, shows that a report by the Council’s Ecologist relating merely to access and biodiversity, was offered to cover for the whole work of the Council’s Open Spaces Department. The PPG17-compliant assessment, described in Diagram 1 (see below for text version of diagram 1) has never been carried out in relation to the open space which Carelet wants to develop.

Residents opposing developments in other areas of Round Hill, should study the procedures below, and ensure that this gross omission is not repeated. In 2007, Brighton and Hove Council enlisted the help of the private consultancy PMP in an attempt to improve its Open Spaces Policy. Although the 2007 Questionnaire sent to selective householders was more complete in its typology, its questions were similarly designed to elicit feedback on how often the respondents gained access to publicly owned open spaces. The questions constrained respondents from offering feedback, for example, on open space which is a visual amenity (without having to gain access to the plot) or privately-owned greenfield sites such as Jan Curry's award-winning wildlife garden, which is accessed by invitation when the owner kindly hosts community events. Brighton and Hove City Council is glad to invite landowners to offer their plots for Wildlife/Garden events. The need is to include these plots in assessments of which greenspaces are valuable to communities. The PPG17 Guidance extends to such plots.

Round Hill residents are therefore correct in their observation that the 2006 and 2007 Questionnaires and Surveys being used by The Council and PMP for data collection, which do not invite respondents to register the amenity-value of Round Hill’s ‘green ribbons’ are going to lead to flawed open spaces studies. Such limited studies cannot be described as fully compliant with the PPG17 Guidance.

Text version of Diagram 1: Redevelopment of an Existing Open Space

SECTION [A]

1. Has the local authority undertaken an assessment that is fully compliant with PPG17? If YES, go to SECTION [B]. If NO, continue…

2. Is the proposed development on an existing playing field? If NO, continue...

3. Has the developer demonstrated through an independent assessment that the land or buildings are surplus to requirements? PPG17, para 10
If NO, refuse permission. If YES, continue…

4. Are the developer’s proposals widely supported by the local community? PPG17, para 10 .
If NO, refuse planning permission. If YES, grant permission subject to a condition or obligation to secure the replacement provision, if required, providing the proposals are acceptable in terms of other relevant policies.

SECTION [B]

5. Is the land surplus to requirements in terms of its present primary use, taking account of the various functions which open space can perform PPG17, para 10 and Annex, para 3 (scroll down to page 14). If YES, go to SECTION [C]. If NO, continue…

6. Will the proposed development secure the conversion of other land to substitute for the loss. If NO, refuse permission. If YES, grant permission subject to a condition or obligation to secure the replacement provision, if required, providing the proposals are acceptable in terms of other relevant policies.

SECTION [C]

7. Is there a deficiency of any other form of open space or sport and recreation provision? PPG17, para 12 If YES, go to SECTION [D]. If NO, continue…

8. Does the land provide an important local amenity and offer recreation and play opportunities? PPG17, para 11 (i) If YES, refuse permission. If NO, continue…

9. Does the land provide a community resource and can it be used for informal or formal events? PPG17, para 11 (ii) If YES, refuse permission. If NO, continue…

10. Does the land particularly benefit wildlife and bio-diversity? PPG17, para 11 (iii) If YES, refuse permission. If NO, grant permission subject to a condition or obligation to secure the replacement provision, if required, providing the proposals are acceptable in terms of other relevant policies.

SECTION [D]

Is there a deficiency of any other form of open space or sport and recreation provision? PPG17, para 12 If NO, continue from question 8 of SECTION [C].
If YES, grant permission subject to a condition or obligation to secure the use of some of the land to reduce the deficit(s), provided the proposals are acceptable in terms of other relevant policies.

Council's reasons for totally omitting the government's procedures Diagram 1: Redevelopment of an Existing Open Space RE Carelet's last application.

(Council's Report and Recommendations / Plans List 1 Feb 2006)

In this case the land in question has difficult access problems and the Council’s Ecologist considers that the only nature conservation feature of note on site was a pond, which was incorporated into the scheme’s design. It is considered that in this particular case it would be difficult to argue the loss of open space as a reason for refusal.

Why this is not good enough

PPG17 paragraph 2.4 and policies in the adopted Local Plan specify a whole range of factors which could describe the amenity-value of 'a green lung' to local residents e.g. the green vista across private gardens, the lines of trees which were important boundary features of our conservation area, the greening contributing to the spectacular view of Round Hill from afar and the trees and vegetation which acted as a dampener for noise, screening local residents from ugly railway garaffiti, the Hollingdean Depot and the Centenary Industrial Estate.

Ease of access is a single determiner of the quality of open space in PPG17. Moreover, there are some instances e.g. wildlife protection where limiting access may preserve amenity. Guidance in PPG17 also extends beyond the brief of The Council's ecologist to ALL the factors mentioned in paragraph 2.4. The necessary assessment should have involved local residents and belongs not to the ecologist but to the Council's Open Space Policy.

How Round Hill residents can act

Take part in the current Consultation on Nature Conservation and Development.

Make clear in your comments that Nature Conservation Surveys carried out by a single Council Officer (usually the Ecologist) should not be used to cover for Open Space Assessments, which inevitable involve many more land uses as well as consultation with the local community. Open Space Needs are meant to be "locally-derived", and not decided by a single Ecologist's Nature Conservation Survey, although the latter may be helpful in establishing one of several uses.

Write to your local representatives - online access to your MP, your 3 local councillors and the 10 South East MEPs representing you in the European Parliament.

See also:
Local residents' comments on Round Hill's Open Spaces provision

See also:
A vision for the open space to the rear of 67 to 81 Princes Rd
PMP's Open Spaces Survey


This page was last updated by Ted on 27-Feb-2008
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