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27 September 2011
ELM/ASU
Department for Environment, Food and Rural Affairs
3/C Nobel House
17 Smith Square
London, SWIP 3JR
Dear Sir
CONSULTATION: REGISTRATION OF NEW TOWN OR VILLAGE
GREENS
I am writing to respond to the consultation document.
The Horsham Society is one of the largest amenity
societies in the south of England with over 1250
members. The Society has been instrumental in
supporting local residents in making applications
under the existing legislation for new town greens,
and in recent years two new greens have been
registered in the town – a 100% success rate.
We have identified a number of other greens which we
believe should be registered in order to protect them
in perpetuity. Town greens are often very different
to the traditional image of a village green but
perform a similar function in providing informal
recreation space and also help to soften the urban
streetscape. They are often the only spaces which can
still support forest trees which were an important
feature of many of our towns but are fast
disappearing.
In our view the case has not been made for change at
the present time. We do not accept that most if not
all greens which are appropriate for registration have
by now been dealt with.
We oppose the introduction of a fee structure. What
the consultation draft fails to recognise is that a
great deal of detailed work in building and evidencing
a case for registration falls on the local community.
Similarly, the benefits of registration accrue not
just to the applicants but future generations. In
areas of towns with a high turnover of residents these
benefits can be multiplied many times. We therefore
consider that it would be unreasonable to charge for
submitting an application.
There is no evidence that the new local space
designation included within the draft National
Planning Policy Framework will offer an adequate route
for protecting areas of green space in and surrounding
towns, particularly given the apparent intention that
it should be used infrequently.
We therefore consider that the current arrangements
should be left unaltered, perhaps for a fixed period
of, say, ten years after which there could be a
further review taking account of experience of use of
the local space designation.
Yours faithfully
John Steele
Secretary, Planning Sub Committee |
