Joint response by Bromley Living Streets and Bromley Cyclists, January 2021

Bromley Living Streets and Bromley Cyclists are groups of Bromley residents who campaign for safer, quieter and lower-traffic neighbourhoods that encourage walking and cycling. By getting more people walking and cycling, we can reduce the number of car journeys, reduce air pollution, create healthier communities and attract business and investment into our high streets.

We are grateful to the council officers and councillors who put tremendous effort into conserving the borough’s open spaces, and we are grateful for their drafting of this strategy document in a year which has been very difficult for almost everyone. However, we have major concerns about the content of the draft strategy document and Bromley Council’s approach to consultation, for which reason we recommend the Council starts afresh. We set out our key asks and concerns below.

Key Asks

1. Level up access to, and standards of, parks and green spaces with particular attention to ‘Areas deficient in Local Parks’ and ‘Areas of Deficiency in Access to Nature’ as defined in the Bromley Local Plan. 

2. Consult with Active Travel stakeholders to devise a borough-wide ‘green grid’ linking parks and green spaces, allotments and sports grounds with a network of walkable/cyclable ‘greenways’ – healthy routes that prioritise safe walking and cycling based on Healthy Streets Indicators.

3. Bring forward recommended actions from the Rights of Way Improvement Plan 2007, and develop mutual strategies in updated/revised ROWIP and OSS.

4. Grow Friends Forum, currently representing around 50 Friends groups, to include Street Friends, Tree Friends and Snow Friends.

5. Promote civic pride with a ‘best kept ward’ award championed by Ward Forums (following Green Flag model).

6. Engage residents with improving green space and biodiversity in their street/neighbourhood, i.e. promoting Tree Friends and planting tree pits, creating wildflower verges

7. Involve LBB Environment officer(s) and idverde with the Health & Wellbeing Board to develop mutual strategies to improve public health.

Key concerns

1. Lack of clarity on responsibilities of different agencies

2. Lack of clear objectives, indicators/targets and theory of change

3. Lack of vision and joined-up thinking

4. Lack of strategy for working with local businesses and community to use Bromley green spaces to increase footfall onto high streets

5. Lack of ethnic diversity in photos

6. Inadequate communication and publicity for the consultation

Detailed comments on content of the draft strategy document

Lack of clarity on responsibilities. We understand that Bromley Friends Forum has asked Bromley Council and idverde on numerous occasions for clarification of responsibilities, including sight of the contract. It would make sense for any consultation document on Bromley’s Open Space Strategy to set out responsibilities, particularly as we believe multiple agencies may be involved (see notes at the end of this document).

Lack of clear objectives, indicators/targets and theory of change. The word ‘strategy’ can be defined as a plan of action designed to achieve an aim. This document is supposed to be a strategy for the coming decade, and Bromley residents are being asked to comment on it, but it contains no objectives, indicators/targets or a theory of change linking the two. It is hard to see, then, what comments Bromley residents can provide, except to ask for a redrafted document that covers these three areas. The organisation responsible for the management and maintenance for the Borough’s blue and green spaces and parks, idverde, have had this contract since March 2015. From reading the draft strategy document, one could be forgiven for thinking that idverde are relatively new to working in the Borough. Conspicuous in their absence are ‘success stories’ (or indeed any kind of a summary) of idverde’s work in Bromley Borough over the past 5 years: all case studies presented in the document are from other boroughs. Why is this?

Lack of vision and joined-up thinking. In these times of COVID-19, climate crisis and fiscal limits, we find it unacceptable that there is  no ‘big picture’ or joined-up thinking covering the Council’s approach to transport and open spaces. Bromley Borough’s green spaces constitute more than 50% of the borough’s area, for which reason idverde’s role in managing them needs to go far beyond providing spaces for people to drive to and walk around. They need to serve a variety of functions, including promotion of biodiversity and – most crucially from the perspective of Bromley Living Streets and Bromley Cyclists – provision of safe and pollution-free routes across the Borough for people travelling on foot or bicycle.

The redrafted document should show how Bromley’s green spaces can serve as active travel links across the borough over the coming decade.  There are already some invaluable walking and cycling routes, e.g. through Norman Park and Jubilee Country Park, but there is scope for much more imaginative thinking in this area.  Given the resounding success of the Waterlink Way that links Penge to Lewisham, Deptford and Greenwich, the Open Spaces strategy might ask if Bromley can create a green route, for pedestrians, cyclists and horse riders close to the Ravensbourne and linking Keston to Bromley Town Centre? Rome wasn’t built in a day, but this is the sort of longer-term planning we would like to see from our elected representatives.

Of course when it comes to park routes, one needs to carefully think through the sharing of space between pedestrians, cyclists and horse riders, and avoid pitting these different modes of travel against each other. The redrafted document should also highlight the well-documented linkages and relationships between active travel, public health, reduction of harmful carbon and gas emissions (e.g. NO2 and PM2.5), and reduction of pressures on Bromley’s roads.

Lack of strategy for working with local businesses and community to use Bromley green spaces to increase footfall onto high streets. Bromley’s fantastic network of green spaces presents the council with a unique opportunity to harness increased interest in rambling and cycling to help bring people to Bromley high streets.  By integrating cycling and walking paths on roads to connect green spaces, Bromley can increase the numbers of people accessing these spaces and the near-by local shops.  An increase in residents and visitors for recreational use of our green spaces will help the hospitality and retail providers near these green spaces; cafes, pubs, restaurants, boutiques, and food purveyors would benefit from increase walking and cycling traffic.  Once this network is established, it will be easier to attract community voluntary and financial support to help maintain the spaces.  

Lack of ethnic diversity in photos. Recent data indicates that ethnic minorities make up 9% of the UK’s population and 1% of the UK’s visitors to the UK countryside (Nick Hayes, 2020, The Book of Trespass, page 156). The argument has been made, in compelling ways, that a major reason for this discrepancy is that ethnic minorities do not feel rural areas in the UK are “for them”. In this context, it is most unfortunate that the Bromley photos in the strategy document are exclusively of white people. This is not acceptable in 2020, a year when issues of discrimination and racism have come to the fore, so we recommend adding photos of ethnic minorities in the redrafted report – as a way of showing that Bromley takes these issues seriously.  

Concerns about Bromley Council’s approach to consultation

Bristol Council has suggested the following “best practice” principles should be considered in any public consultation:

  • Time consultations well and allow sufficient time to respond
  • Clearly present relevant information and encourage informed opinion
  • Be well targeted and reach out to hard-to-reach groups
  • Offer genuine options and ask objective questions
  • Be well planned, managed and co-ordinated
  • Be listed on consultation finder and be well communicated
  • Provide fair, accessible feedback

Sadly, while we applaud the council for arranging a Public Consultation on this most important of issues and acknowledge the pressures of the pandemic on staffing, this consultation and draft OS Strategy do not really follow best practice. One reason, alluded to above, is the problematic content. This is a 10 year strategy: there are no specific actions or timescales. Lots of “reviews”, “develop”, nothing concrete, no imaginative vision, no commitments, it’s just about “a direction of travel”. No milestones or measures of success. We should expect more of a contractor who has won such a lengthy, impactful and lucrative contract. There is no information on funding, which is of particular concern given that we have reason to believe that the budget allocated for the maintenance of all Rights of Way in the borough in 2020/21 is £60K. Instead the document seems to suggest reducing maintenance costs and increasing income generated by the parks and open spaces, which can only be to the detriment of our green spaces.

There has also been inadequate communication and publicity: Bromley issued a single website press release about the consultation, on 12 November and a tweet on 13 November, but there was no mention on the Council’s Facebook page or in the Winter 2020 Environment Matters newsletter. This is particularly shocking given that the document itself states that 

“The Council values its communities, partners, residents and stakeholders and will engage them in reviewing this strategy and consult them on open space management plans and major developments within local open spaces.”  (page 36)

In conclusion, we believe the document needs to be completely redrafted.

Notes

Bromley in comparison to other boroughs

Key figures on modes of travel:

  • In Bromley borough, the annual traffic by motor vehicles has increased from 800 million to a billion between 2009 and 2019
  • Bromley has more cars per household than any other borough – up 5% since 2010
  • Bromley has the second highest number of diesel cars of any borough – 39,767
  • Bromley has fewer active air quality monitors than almost any other borough (it has one, which is poorly located)

Here are some links to other borough’s Open Space Strategies and related documents:

The case for joined-up thinking

The ‘Open Space Strategies: best practice guidance‘ document, produced by the GLA and CABE under Boris Johnson’s tenure as Mayor, asks the question: Why produce an open space strategy? and answers that question as follows:

The benefit of preparing a strategy is the protection and creation of a network of high-quality open spaces that can: 

  • reinforce local identity and civic pride
  • enhance the physical character of an area, shaping existing and future development  
  • improve physical and social inclusion, including accessibility
  • provide connected routes between places for wildlife, recreation, walking and cycling, and safer routes to schools
  • protect and enhance biodiversity and ecological habitats
  • provide green infrastructure and ecosystem services
  • provide for children and young people’s play and recreation
  • raise property values and aid urban regeneration
  • boost the economic potential of tourism, leisure and cultural activities
  • provide cultural, social, recreational, sporting and community facilities
  • protect and promote understanding of the historical, cultural and archaeological value of places
  • contribute to the creation of healthy places, including quiet areas
  • provide popular outdoor educational facilities
  • promote the opportunities for local food production
  • help mitigate and adapt to climate change
  • improve opportunities to enjoy contact with the natural world.

This is followed on p6 by “An open space strategy should make reference to a range of other corporate strategies within a local authority” with examples of linked strategies: Regeneration strategy, Health strategy, Culture strategy, Education strategy, Crime and disorder strategy, Local transport plans and strategies, Climate change strategy, Biodiversity strategy, Equalities and access strategy

There are often calls for more joined-up thinking from Bromley Council, and the OSS is no exception. There are other relevant strategies but little evidence of clearly linked themes even within Environment & Community Services (E&CS) silo publications, let alone silos including Regeneration and Public Health. We would welcome better integration between E&CS and Public Health within Bromley Council, including representation of Open Space team and Friends Groups on Health & Wellbeing Board (H&WB).

Background on idverde in London Borough of Bromley

In March 2015, LB Bromley Councillors approved the merger of the Council’s Parks, Greenspace & Countryside management service with The Landscape Group (TLG) – subsequently renamed idverde – grounds maintenance team to create one integrated management and maintenance service with the following agreed priorities:

  • Enhance the high level of service achieved in recent years 
  • Increase the responsiveness of the service to stakeholder groups 
  • Deploy resources more flexibly to reflect stakeholder preferences or available funding 
  • Reduce the cost of the service through increasing productivity 

A draft 48-page Greenspace Strategy was circulated in September 2015, with a final version published in 2016 including an appendix listing the following outcomes and objectives (with associated projects):

Strong, inclusive and connected communities

  • Promote participation in volunteering and expand membership of Friends Groups. 
  • Support and mentor community groups to increase their involvement and capacity for self-help including the securement of external funding.
  • Through community empowerment, enhance opportunities with regard to local wishes for play, recreation, sports,leisure gardens and allotments.
  • Work with external agencies to deliver greater community outcomes.

Attractive, biodiverse, and sustainable parks, greenspace and countryside

  • Protect and promote the range of habitats including those on land, water and marginal areas and designated sites through appropriate and sustainable landscape management, following best practice guidelines in the Bromley Biodiversity Action Plan.
  • Provide welcoming and accessible parks, open spaces, countryside and woodlands, maintained to high standards, that reflect the needs of the community and its heritage.
  • Transform the Bromley Environmental Education Centre at High Elms (BEECHE) into a financially sustainable centre of excellence.
  • Ensure that the parks management service is accessible to all users and visitors.

Quality services and value for money

  • Design a new community-focused and totally integrated approach to green space management to achieve the highest standards possible within the resources available.
  • Enhance the financial sustainability of the Service by increasing resources through new and innovative funding streams that benefit greenspace.
  • Train and develop TLG’s management and workforce.
  • Introduce performance reporting and quality monitoring mechanisms to ensure that high standards are maintained and continually improved.

https://idverde-ebcf.kxcdn.com//wp-content/uploads/2016/04/16.04-Bromley-Green-Space-Strategy.compressed.pdf

Four years on, in 2019, “Bromley Council took the bold decision to award an innovative 8-16 year contract to idverde … for the management and maintenance of its blue and green spaces and parks”. Announced via a press release, the re-awarded contract commenced on 1st April 2019.


A further 20 months on another press release announced the Draft Open Space Strategy 2021-2031 Consultation.

Agencies and their responsibilities

1. Trees are still managed by the Council’s Tree Officers and, since April 2019, maintained by Glendale. 

2. Natural streams and rivers, and ponds/lakes they feed or are fed by, are managed/overseen by the Environment Agency and local catchment groups, with only limited maintenance work carried out by id verde rather than other contractors and volunteers.

3. Infrastructure and hard landscaping repairs and maintenance is referred by the Council to its ‘property’ contractor Amey (under review I believe). Direct contact between Friends Forum or Groups with Amey is discouraged and repairs remain outstanding for months/years. 

4. The Council is responsible for park signs, most of which are in a poor state of repair and with out-of-date information (except for those in/around central Bromley). 

5. Ward Security is responsible for opening/closing parks and ongoing security.

6. Chislehurst Commons are managed/maintained separately from LBB.

7. West Wickham Common is owned/managed/maintained by the City of London. 

8. idverde, not Veolia, empty litter bins and collect rubbish in parks and deliver to Bromley central depot. Neither LBB or contractors subscribe to Keep Britain Tidy campaigns, relying on friends/community groups and residents to promote.