Page 1 - Open Space Strategies
1. (a). Do you agree with the idea of promoting an outcomes-based approach through the Open Space Strategies Regulations?
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Yes
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No
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No view
Any comments?
Measurement of outcomes should be built up from the local, settlement level to understand provision. A top-down, national measure would risk obscuring needs, issues and solutions.
1. (b). Do you agree with the suggested outcomes?
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No
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Any comments?
The outcomes should also include the value of local landscape management, which encompass the proposed outcomes, but ensure these are managed holistically. Maintaining and enhancing landscapes will also being in the cultural element of open spaces - how landscapes are created, understood and maintained.
There is reference in the outcomes to "green networks". The National Trust for Scotland, along with other organisations, is calling for the creation of a National Nature Network, which would connect up areas of high nature value. There needs to be greater clarity as to what is meant by a "green network" and how this relates (or does not) to the national nature network concept in the National Planning Framework.
There is reference in the outcomes to "green networks". The National Trust for Scotland, along with other organisations, is calling for the creation of a National Nature Network, which would connect up areas of high nature value. There needs to be greater clarity as to what is meant by a "green network" and how this relates (or does not) to the national nature network concept in the National Planning Framework.
2. Do you agree with the proposed definition of:
(a) ‘open space’ Yes Radio button: Not checked Yes | (a) ‘open space’ No Radio button: Not checked No | (a) ‘open space’ No view Radio button: Checked No view |
(b) ’green space’ Yes Radio button: Checked Yes | (b) ’green space’ No Radio button: Not checked No | (b) ’green space’ No view Radio button: Not checked No view |
(c) ‘green infrastructure’ Yes Radio button: Checked Yes | (c) ‘green infrastructure’ No Radio button: Not checked No | (c) ‘green infrastructure’ No view Radio button: Not checked No view |
(d) 'green networks’ Yes Radio button: Not checked Yes | (d) 'green networks’ No Radio button: Checked No | (d) 'green networks’ No view Radio button: Not checked No view |
(e) 'ecosystem services’ Yes Radio button: Checked Yes | (e) 'ecosystem services’ No Radio button: Not checked No | (e) 'ecosystem services’ No view Radio button: Not checked No view |
(d) 'green networks’ definition - Any comments?
As above. The need for a national nature network has been identified, linking together areas of high nature value across Scotland, to ensure greater resilience for our biodiversity.
The definition of "green networks" falls short of this ambition. If the network is meant for human amenity, then it is adequate. If it is intended for nature recovery, then it will need a more ambitious definition, including reference to species, habitats and connectivity.
The definition of "green networks" falls short of this ambition. If the network is meant for human amenity, then it is adequate. If it is intended for nature recovery, then it will need a more ambitious definition, including reference to species, habitats and connectivity.
3. Do you agree with proposed thresholds for open space audits in Draft Regulation 4(2)?
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Yes
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No
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No view
4. (a). Do you agree with suggested information to include about each open space (location, size and type)?
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Yes
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No
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No view
Any comments?
Biodiversity - if the intention is to use the open space strategy to assist with nature recovery, then a greater degree of information will be needed on species and habitats, and their condition, in these audits.
Culture - the proposed "types" do not include cultural spaces, such as battlefields, Gardens & Designed Landscapes, or other cultural associations. By including the cultural value of open spaces, the strategy will better connect with how people understand and value these spaces.
Climate change - along with nature recovery, our open spaces will have an important role in managing climate change. The type and condition of land cover in our open spaces will therefore be relevant to natural capital and ecosystem services planning.
Culture - the proposed "types" do not include cultural spaces, such as battlefields, Gardens & Designed Landscapes, or other cultural associations. By including the cultural value of open spaces, the strategy will better connect with how people understand and value these spaces.
Climate change - along with nature recovery, our open spaces will have an important role in managing climate change. The type and condition of land cover in our open spaces will therefore be relevant to natural capital and ecosystem services planning.
4. (b). Do you agree with Regulation 4(5) on the other information planning authorities may include in the audit?
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Yes
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No
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Any comments?
As above, the biodiversity, cultural and natural capital value of open spaces should also be considered.
5. (a). Do you agree with the suggested approach to require locality level place-based information?
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No
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5. (b). Do you agree with the three high level aspects that should be covered in these statements ‘accessibility’, ‘quantity’ and ‘quality’?
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Yes
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No
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No view
Any comments?
As above, biodiversity, cultural value, and natural capital (suggested by the reference to climate change in this section of the text) should be part of the qualitative assessment.
6. Do you agree with the list of consultees for the open space audit?
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Yes
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No
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No view
7. (a). Do you agree the Assessment of Current and Future Requirements should have regard to how open spaces and green networks in the area are contributing to the outcomes?
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Yes
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No
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No view
Any comments?
We agree with the inclusion of biodiversity in the assessment of outcomes - this will require a much higher degree of detail in the "types" mentioned in section 32.
The cultural value, and natural capital value of open spaces should also form part of the assessment.
The cultural value, and natural capital value of open spaces should also form part of the assessment.
7. (b). Do you agree with the proposed provisions for the Assessment of Current and Future Requirements for the assessment to be informed by engagement with the groups set out?
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Yes
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No
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No view
8. (b). Do you agree Open Space Strategies should identify strategic green networks?
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Yes
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No
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No view
Any comments?
The consultation document has no definition of "strategic green networks." It is therefore not possible to know what is meant by the use of this term.
The need has been identified for a national nature network, connecting high nature value areas across Scotland in order to underpin nature recovery. This will require assessing the species and habitats affected, and how best these can be connected.
There is a risk that an undefined "green network", which may be of low biodiversity benefit (e.g. a strip of closely mown grass) is substituted for a nature network.
We would prefer reference to be made to a nature network where improving biodiversity is one of the objectives.
The need has been identified for a national nature network, connecting high nature value areas across Scotland in order to underpin nature recovery. This will require assessing the species and habitats affected, and how best these can be connected.
There is a risk that an undefined "green network", which may be of low biodiversity benefit (e.g. a strip of closely mown grass) is substituted for a nature network.
We would prefer reference to be made to a nature network where improving biodiversity is one of the objectives.
8. (c). Do you agree Open Space Strategies should identify how green networks may be enhanced?
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Yes
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No
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No view
Any comments?
As above. At present, the meaning of a "green network" and its relationship, if any, to nature recovery is unclear. Where improving biodiversity is the objective, then the term nature network is preferred.
9. Do you agree with the proposed consultation requirements on draft Open Space Strategies?
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Yes
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No
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No view
10. Do you agree with the proposed publication requirements for Open Space Strategies?
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Yes
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No
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No view
11. Do you agree the Regulations should set a 10 year minimum review period for updating open space audits and strategies?
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Yes
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No
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No view
Page 2 - Play Sufficiency Assessments
12. Do you agree with the proposed definitions?
(a) “children" Yes Radio button: Checked Yes | (a) “children" No Radio button: Not checked No | (a) “children" No view Radio button: Not checked No view |
(b) “localities” Yes Radio button: Checked Yes | (b) “localities” No Radio button: Not checked No | (b) “localities” No view Radio button: Not checked No view |
(c) “open space” Yes Radio button: Checked Yes | (c) “open space” No Radio button: Not checked No | (c) “open space” No view Radio button: Not checked No view |
(d) “play spaces” Yes Radio button: Checked Yes | (d) “play spaces” No Radio button: Not checked No | (d) “play spaces” No view Radio button: Not checked No view |
13. Do you agree planning authorities should map the locations of the two categories of play spaces, and how they are described in Draft Regulations 3(2)(a) and (b)?
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Yes
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No
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No view
14. Do you agree with the proposed requirement to assess play opportunities in respect of their suitability by age groups?
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No
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15. (a). Do you agree with the proposed three aspects of assessment - ‘accessibility’, ‘quantity’ and ‘quality’?
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Yes
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No
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No view
Any comments?
The assessment should include the condition of the assets, as well as their presence. Accepting the reviews may be 10-years apart, knowing which assets were in a safe and usable condition, and where these are located (which in turn can be linked to the wellbeing of communities), will help assess provision.
15. (b). Do you agree to provide them in written statements in respect of the totality of the local authority area and at each locality level?
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Yes
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No
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No view
16. (a). Do you agree to the requirement to consult as part of the process of carrying out the play sufficiency assessment?
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16. (b). Do you agree with the proposed list of consultees on play sufficiency assessments?
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Yes
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No
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No views
17. Do you agree with the publication requirement for play sufficiency assessments?
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Yes
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No
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No views
Page 3 - Impact Assessments
18. Do you have or can you direct us to any additional information that would assist in finalising these assessments (BRIA, EQIA, CRWIA, ICIA)?
Please add your comments here:
Landscape is important to communities and how they understand and relate to their local open spaces. These may also be designated (e.g. battlefields, Gardens and Designed Landscapes, Special Landscape Areas, etc.). Historic and natural landscapes are also mapped, and available as GIS data.
20. Do you agree with the Fairer Scotland Duty screening and our conclusion that full assessment is not required.
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Agree
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Disagree
21. Do you agree with the Strategic Environmental Assessment pre-screenings, that the Open Space Strategies and Play Sufficiency Assessments Regulations are exempt from the Environmental Assessment (Scotland) Act 2005, as the environmental effects are likely to be minimal?
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Disagree
Please add your comments here:
If the intention is to use green spaces as part of national efforts on nature recovery, then it would be helpful to understand the expected reach and impact of the regulations on biodiversity.
If you consider full assessments are required please suggest any additional sources that could help inform these assessments
For Strategic Environmental Assessment, data on biodiversity (including location and condition and management measures) are available from NatureScot, including for protected areas, and natural spaces.
22. Any other comments?
Please detail below:
As mentioned above, the cultural value, and the natural capital value of our open spaces should form part of the assessment. A landscape approach would help bring these and other elements together, and be a gateway to working with communities on how these spaces evolve.
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