Gardens & wildlife

Objection to Open Spaces Survey

Link back to main article on PMP / Brighton and Hove Council's latest Open Spaces Survey

1. Sample letter/message of complaint to send to PMP
(see contact us page on their web site).

A similar complaint could also be sent to:
Brighton and Hove City Council's
Open Spaces Department,
Open Space Survey,
Planning Strategy & Projects Team
City Planning,
Brighton and Hove City Council,
Hove Town Hall – Room 414,
Norton Road, Hove BN3 3BQ


To: Marj Lawson, Research Consultant for PMP.


I am very concerned about the failure of the Open Space Survey, conducted by PMP for Brighton and Hove City Council, to comply with The Government's Planning Policy Guidance 17 Companion Guide: Assessing needs and opportunities.

Your survey's lack of compliance has serious implications for the future of open spaces in the neighbourhood where I Iive.

The emphasis on public open spaces (completely outside our neighbourhood - we haven't got any) marginalizes the very open spaces which are really under threat and which our community has been fighting to preserve and enhance.

The procedures described in the Government's Companion Guide for Councils undertaking open space assessment include diagram 1 and paragraph 10, which apply to private land as well as publicly accessible sites. The application of these would help to prevent the erosion of open spaces in our conservation area.

Brighton and Hove City Council's Local Plan QD 28 Planning Obligations - policy 3.118 RE greenfield/brownfield (see footnote 1) should also help us in this regard.

However, sites of quite different statuses have been bundled together as single proposed development sites without any transparency: i.e. identification by the Council of what is "greenfield" or "brownfield". It has been left to local residents and The Round Hill Society to study PPS 3 Annex B: Definitions (scroll to p26 of the PDF doc link or see footnote 2 below) and to pay for legal advice on greenfield / brownfield classifications in order to be sure of our ground while campaigning to prevent loss of valued open spaces. Many such campaigns are described on The Round Hill Society's web site at www.roundhill.org.uk.

Question 1 in your survey, which asks for comment on Public Open Spaces outside Round Hill could well represent all that the Council plans to protect from development. The outcome of your survey would then be to devalue the private open spaces within Round Hill. The "city-wide" context of your question would then be a smokescreen, since your quantitative analysis should (under PPG17) relate to specific neighbourhoods.

The PPG17 Guidance paragraph 4.19 on Assessing the Adequacy of the Amount of Existing Provision suggests that surveys focus on identifiable neighbourhoods, separated from adjoining areas such as railways lines (the northern boundary of Round Hill) and perceptual barriers such as areas which are perceived to be unsafe (e.g. Upper Lewes Rd - regarded by many residents as a death trap to the south and east, and Ditchling Rd to the west - a main route into Brighton from the north which gets busier ever day). The Guidance does not ask for residents to consider the quantity of open spaces throughout the whole of their city.

Open Space Needs are locally-derived under PPG17 and the very point of open space visions is that they come from the community. We decide on the taxonomy of open spaces IN OUR NEIGHBOURHOOD for which we have visions (bad ones I'm afraid if they are not represented at all in an open-space survey which has been doctored to exclude them).

I suggest that PMP and Brighton and Hove City Council allow The Round Hill Society and Round Hill residents to draw up a list of the open spaces we value in Round Hill. These should then be the focus of local comment. If Round Hill residents feel that our Council's survey is being used in any way to exclude these open spaces, then we will be forced to expose the survey's non-compliance with PPG17 in the local and national media. The Planning Inspectorate is already aware of our disquiet and I plan to raise this with other government agencies as well as Local Councillors. I would expect particular interest from the consultees who argued for safeguards for private open space in the drafting of PPG17.

This survey is not about protecting the open spaces which are actually under threat. I fear that the real use will be to help the Council to meet its housing targets in the worst way, through urban cramming and asset-stripping our hillside community of its open spaces. The Government's Companion Guide to PPG17 shows quite clearly how truly-compliant open space assessment should proceed if that's what the Council really wanted to achieve.

The questionnaire's first question on QUANTITY, should not be city-wide. It should be to allow us to identify the shortage of public open space and to comment on the importance of private open space in our particular neighbourhood.

Nowhere in the questionnaire are we given this opportunity. Neighbourhood-specific factors (mentioned in PPG17: 3.5 of the Companion Guide) also include the amount of private greenspace, the age and social structure of the local population, together with its distribution and the density of development.

Local attitudes are also important, and there is strong evidence in Round Hill (events such as Open Gardens, Jan Curry's national award-winning wildlife garden in the heart of our area, the 800 letters involving 400 Round Hill households objecting to the developer Carelet's proposals affecting the Conservation Area's greenbelt) that people value private open space on inaccessible hillside plots.

We don't need to get into cars to travel to these open spaces. It is far better for our urban environment that we live among them. They are visible every day of our lives. Urban cramming will only ensure that those with cars will have to get into them to have any access to open spaces on more than an infrequent basis.


The Policy of our Local Plan RE greenfield/brownfield development and the definitions of "greenfield" and "brownfield"
Footnote 1:

Policy (QD 28 Planning Obligations) 3.118 from Brighton and Hove City Council's Local Plan:

"This council attaches the highest priority to the protection of previously undeveloped (greenfield) land. Previously built on (brownfield) land must therefore be developed in preference to previously undeveloped (greenfield) land. If an applicant seeks to develop a greenfield site they will be expected to demonstrate that there are no alternative brownfield sites that could meet their requirements."

Footnote 2:

Planning Policy Statement PPS 3 Annex Definitions B:
(November 2006):

Previously-developed land (often referred to as brownfield land)

‘Previously-developed land is that which is or was occupied by a permanent structure, including the curtilage of the developed land and any associated fixed surface infrastructure.’

The definition includes defence buildings, but excludes:
– Land that is or has been occupied by agricultural or forestry buildings.
– Land that has been developed for minerals extraction or waste disposal by landfill purposes where provision for restoration has been made through development control procedures.
– Land in built-up areas such as parks, recreation grounds and allotments, which, although it may feature paths, pavilions and other buildings, has not been previously developed.
– Land that was previously-developed but where the remains of the permanent structure or fixed surface structure have blended into the landscape in the process of time (to the extent that it can reasonably be considered as part of the natural surroundings).

There is no presumption that land that is previously-developed is necessarily suitable for housing development nor that the whole of the curtilage should be developed

2. Sample Press Release to send to local &/or national media
Questionnaires have been sent to a random selection of households in Brighton and Hove by PMP, a consultancy currently commissioned by the Council to deliver a study on open spaces within our city.

On the surface, this looks a better survey than the Council's 2005 in-house study. As well as parks and recreation grounds, the definition of open space extends to woodlands and scrubland, green corridors, outdoor sports facilities, teenagers' and children's recreation & play areas, amenity green space within housing developments, allotments, cemeteries, churchyards, gardens and civic spaces.

The problem is that each question in PMP's survey stipulates open spaces which residents actually use and asks for tick-boxes to be filled in to indicate the length of time it takes to get to them.

Such a survey is useless to conservation areas such as Round Hill Brighton, which has no open spaces accessible for public use.

Both the Council's 2005 Open Spaces Study and the current PMP survey fall short of the Government's Planning Policy Guidance PPG17 by overlooking the contribution of private open spaces to wildlife, biodiversity, green vistas across private gardens, boundary features and public viewpoints from afar, such as the spectacular views of Round Hill from the top of Bear Road and parts of Woodvale.

Government Planning Policy Guidance PPG17 makes it quite clear that: just because an open space is inaccessible or privately-owned, it does not mean that it is irrelevant to the health and well-being of communities and therefore to be excluded from Open Space Studies.

In recent years, Round Hill residents have had to fight proposals to develop the greenfield site adjacent to the Coastways railway corridor, which screens residents living to the NE of our area from both Hollingdean Depot and the Centenary Industrial Estate. We have also had to oppose an application to develop part of the much valued greenway (Round Hill's 'jewel-in-the-crown') running either side the Cats Creep steps between Richmond Road and Round Hill Crescent.

PMP´s insistence on public access to open spaces, entirely misses the point. The only legal access we will get to our railway corridor is on a Coastways train. We can only actually set foot on green ribbons such as Jan Curry´s award-winning wildlife garden with the landowner´s permission. However, in order to appreciate these open spaces, we do not need direct access or journeys to them, because we live among them.

Government Guidance on how to conduct open space surveys recognises the value of these hillside open spaces, which are clearly going to be inaccessible but are still very visible to residents. PMP's open space questionnaire completely fails in this regard.

PMP is offering an Open Spaces Prize Give-away to encourage householders to fill in their survey. However, their questionnaire threatens to give away the only open spaces we have in a conservation area, noted for its green ribbons and period architecture.

This page was last updated by Ted on 04-Sep-2007
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