Response 545680184

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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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Radio button: Unticked Yes
Radio button: Unticked No
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1. (b). Do you agree with the suggested outcomes?

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Radio button: Unticked Yes
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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: Not checked Yes (b) ’green space’ No Radio button: Not checked No (b) ’green space’ No view Radio button: Checked No view
(c) ‘green infrastructure’ Yes Radio button: Not checked Yes (c) ‘green infrastructure’ No Radio button: Not checked No (c) ‘green infrastructure’ No view Radio button: Checked No view
(d) 'green networks’ Yes Radio button: Not checked Yes (d) 'green networks’ No Radio button: Not checked No (d) 'green networks’ No view Radio button: Checked No view
(e) 'ecosystem services’ Yes Radio button: Not checked Yes (e) 'ecosystem services’ No Radio button: Not checked No (e) 'ecosystem services’ No view Radio button: Checked No view

3. Do you agree with proposed thresholds for open space audits in Draft Regulation 4(2)?

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Radio button: Unticked Yes
Radio button: Unticked No
Radio button: Ticked No view

4. (a). Do you agree with suggested information to include about each open space (location, size and type)?

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Radio button: Unticked Yes
Radio button: Unticked No
Radio button: Ticked No view

4. (b). Do you agree with Regulation 4(5) on the other information planning authorities may include in the audit?

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Radio button: Unticked Yes
Radio button: Unticked No
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5. (a). Do you agree with the suggested approach to require locality level place-based information?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked No view
Any comments?
As shown in the 2016 Scottish Household Survey, availability of play areas differ depending on levels of deprivation, particularly in urban areas. Parents and children living in the most deprived areas showed higher safety concerns about accessing play areas and travelling to play areas, with open spaces also often being of poorer quality. It is particularly important that the Open Space Strategy Regulations address this inequity which has a direct impact on the breadth of development of children at all ages, their wellbeing and their quality of childhood experiences. Open Space Strategy Regulations could be a tool to remedy such inequalities in access to play and open outdoor spaces, if particular attention is paid to the experiences of children and families in the most deprived areas, as well as children and families who experience poverty and low income who may not live in the most deprived areas. It is therefore particularly relevant to provide assessments at locality level to understand the potential gaps and barriers for accessing play and open spaces.

5. (b). Do you agree with the three high level aspects that should be covered in these statements ‘accessibility’, ‘quantity’ and ‘quality’?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked No view
Any comments?
These are suitable and relevant aspects for assessment. They should be used in their widest meaning: “Accessibility” should be considered both from a perspective of “travel to a space” as well as places that “include every child”.

In relation to travel to a location, particular emphasis should be given to safety aspects, distance and perceived safety of the location which impacts on the willingness of both children and parents to access an open space. Many children and families experiencing poverty or low income have told us that there is a lack of safe and accessible open spaces. This may be due to spaces not being in walking distance, lack of access to a car or cost of public transport. It may also be due to local open spaces being of poor quality or being perceived as unsafe. It may be because the route to an open space involves navigating through traffic and crossing main roads which are not safe. Families and children experiencing poverty or low income may not have access to a car to travel a distance to an open space that is not local. Travel by public transport incurs significant costs and may therefor also not be an option. There is thus a particular need to ensure that families and children experiencing poverty and/ or low income, have access to local open spaces that can be accessed by walking or wheeling on safe routes. The Open Space Strategies Regulations presents and opportunity to identify gaps in local provision of open spaces and to remedy these. They should ensure that gaps in provision of open spaces particularly in areas of low income are identified and remedied.

Accessibility includes safety from (particularly motorised) traffic, ensuring that there is no pavement parking, safe pedestrian routes (this includes well maintained pavements) and safe cycling routes to each open space. Such low cost forms of transport should be enabled by being the easiest and safest mode of transport. Parts of open spaces should provide an area of car free environment for enjoyable and worry free play. At the same time, the needs of disabled children or parents, elderly carers of children such as grandparents need to be addressed too. This means that access to open spaces by car needs to be provided too for accessibility as well as inclusivity of play.

Open spaces should be welcoming for all age and ability groups and provide clean, safe and challenging places for the full age range being catered for.

Finally, another aspect of accessibility is an understanding by all who care for children of how open spaces can be used as play spaces. This may involve promotion and awareness raising of the types of outdoor play which particularly take place in spaces that are not assigned as play spaces so that everyone caring for children can make the most use out of them and value their contribution to children’ physical, cognitive and social/emotional development.

6. Do you agree with the list of consultees for the open space audit?

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Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked No view
Any comments?
We welcome that children, young people and parents/carers are included. We would suggest representatives from groups identified as not currently enjoying equity in access to green spaces are consulted, which includes children and families living in poverty or on low income with representation from the priority groups as outlined in the Child Poverty Delivery Plan: Families with a disabled child, single parent families, families with 3 or more children, families where the mother is 25 or younger, families with a child under one, and BAME Families.

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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Radio button: Unticked Yes
Radio button: Unticked No
Radio button: Ticked No view

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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Radio button: Unticked Yes
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Radio button: Ticked No view

8. (a). Do you agree Open Space Strategies should include a statement setting out how they contribute to the outcomes?

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Radio button: Unticked Yes
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Radio button: Ticked No views

8. (b). Do you agree Open Space Strategies should identify strategic green networks?

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Radio button: Unticked Yes
Radio button: Unticked No
Radio button: Ticked No view

8. (c). Do you agree Open Space Strategies should identify how green networks may be enhanced?

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Radio button: Unticked Yes
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9. Do you agree with the proposed consultation requirements on draft Open Space Strategies?

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Radio button: Unticked Yes
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Radio button: Ticked No view

10. Do you agree with the proposed publication requirements for Open Space Strategies?

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Radio button: Unticked Yes
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Radio button: Ticked 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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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)?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked No view

14. Do you agree with the proposed requirement to assess play opportunities in respect of their suitability by age groups?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked No view
Any comments?
We agree with the importance of assessing suitability for different age groups, however some of the age ranges of types of play and characteristics of spaces could be adjusted:

The age ranges of some types of play could be extended – specifically “building dens” could be extended to 0-4 year olds if the activity is undertaken jointly with a guardian. “Water for pouring, measuring or splashing” is still relevant for 5-11 year olds depending on set up and size of play activity.

In relation to the section on characteristics of play, the play place should also be easy to walk to or wheel/cycle should be extended to 0-4 year olds, and feel safe for this age group too, bearing in mind that balance bikes, trikes may be used for transport from two years onwards and that even the youngest walkers should be able to walk safely if they choose to do so.

15. (a). Do you agree with the proposed three aspects of assessment - ‘accessibility’, ‘quantity’ and ‘quality’?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked No view
Any comments?
These are suitable and relevant aspects for assessment. They should be used in their widest meaning: “Accessibility” should be considered both from a perspective of “travel to a space” as well as places that “include every child”.

In relation to travel to the location, particular emphasis should be given to safety aspects, distance and perceived safety of the location which impacts on the willingness of both children and parents to access a space to play. Many children and families experiencing poverty or low income have told us that there is a lack of safe and accessible play and open areas. This may be due to play spaces not being in walking distance, lack of access to a car or cost of public transport. It may also be due to local play spaces being of poor quality or being perceived as unsafe. It may be because the route to an open or play space involves navigating through traffic and crossing main roads which are not safe. Families and children experiencing poverty or low income may not have access to a car to travel a distance to an open or play space that is not local. Travel by public transport incurs significant costs and may therefor also not be an option. There is thus a particular need to ensure that families and children experiencing poverty and/ or low income, have access to local play and open spaces that can be accessed by walking or wheeling on safe routes. The PSA presents and opportunity to identify gaps in local provision of play and open spaces and to remedy these. PSA should ensure that gaps in provision of open and play spaces particularly in areas of low income are identified and remedied.

Accessibility includes safety from (particularly motorised) traffic, ensuring that there is no pavement parking, safe pedestrian routes (this includes well maintained pavements) and safe cycling routes to each outdoor play or open space. Such low cost forms of transport should be enabled by being the easiest and safest mode of transport. Play spaces and parts of open spaces should provide an area of car free environment for enjoyable and worry free play. At the same time, the needs of disabled children or parents, elderly carers of children such as grandparents need to be addressed too. This means that access to play and open spaces by car needs to be provided too for accessibility as well as inclusivity of play.

Play and open spaces should be welcoming for all age and ability groups and provide clean, safe and challenging places for the full age range being catered for.

Finally, another aspect of accessibility is an understanding by all who care for children of how open spaces can be used as play spaces. This may involve promotion and awareness raising of the types of outdoor play which particularly take place in spaces that are not assigned as play spaces so that everyone caring for children can make the most use out of them and value their contribution to children’ physical, cognitive and social/emotional development.

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?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked No view
Any comments?
As shown in the 2016 Scottish Household Survey, availability of play areas differ depending on levels of deprivation, particularly in urban areas. Parents and children living in the most deprived areas showed higher safety concerns about accessing play areas and travelling to play areas, with play areas also often being of poorer quality. It is particularly important that the play sufficiency assessments address this inequity which has a direct impact on the breadth of development of children at all ages, their wellbeing and their quality of childhood experiences. Play sufficiency assessments could be a tool to remedy such inequalities in access to play and open outdoor spaces, if particular attention is paid to the experiences of children and families in the most deprived areas as well as children and families who experience poverty and low income who may not live in the most deprived areas. It is therefore particularly relevant to provide assessments at locality level to understand the potential gaps and barriers for accessing play and open spaces.

16. (a). Do you agree to the requirement to consult as part of the process of carrying out the play sufficiency assessment?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked No views
Any comments?
Consulting with parents/carers and children in particular will provide the perspective of the users of play and open spaces. Understanding their perceptions, barriers to access, as well as views on quality and quantity of spaces will provide insights to ensure play spaces are accessed and used. It can also identify opportunities that may not otherwise have been considered. Consulting with them should be a priority and be given most weight due to the life long impact of access to and use of open and play spaces on the wellbeing, physical and mental health, and learning and development of children.

We welcome that children, young people and parents/carers are included. We would suggest representatives from groups identified as not currently enjoying equity in access to green spaces are consulted, which includes children and families living in poverty or on low income with representation from the priority groups as outlined in the Child Poverty Delivery Plan: Families with a disabled child, single parent families, families with 3 or more children, families where the mother is 25 or younger, families with a child under one, BAME Families.

Save the Children developed Children’s Places, with support from the STV Children’s Appeal, as practical model for engaging children and families in decision-making. The programme has demonstrated how co-designing play spaces can have a positive impact on making sure they are inclusive, utilised and meet the needs of a community. Through the programme, two outdoor play areas were created, a children’s play area in Glenburn, Renfrewshire and a sensory garden in South Lanarkshire: Children’s Places blends principles from family learning, community development and engagement and place-based approaches to engage and empower communities to improve the lives of young children experiencing poverty in Scotland.

We supported Stronger Communities Glenburn to perform a community wide consultation on the location and design of the play park and to apply for funding from the council. The results of the consultation with children prioritised some key pieces of equipment that have been included in the design specifications to ensure the park reflects what local children want. We further co-designed the ‘Chatty Challenge’, an initiative aimed at improving language acquisition and positive parental engagement on the nursery run and in the play park.

16. (b). Do you agree with the proposed list of consultees on play sufficiency assessments?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked No views
Any comments?
We agree with the proposed list of consultees. We would suggest consideration is given to weighting the views of different groups and that the best interests and views of parents and children are given priority. Other potential stakeholders for consultations could be childminders and other childcare providers who make regular use of outdoor play spaces and will have significant experience in recognising quality, access, and quantity in relation to play spaces. We would highlight the need to ensure that the voices of children and parents living in low income communities are proactively sought to ensure that issues of inequality in access to open spaces and play spaces is remedied. These should also mean to proactively include families who represent the six priority groups as identified in the Child Poverty Delivery Plan (families with a child under one, families with a disabled child, families with three or more children, BAME families, single parent families, young mothers)

17. Do you agree with the publication requirement for play sufficiency assessments?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked No views

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