Open Space Strategies and Play Sufficiency Assessments

East Lothian Council is grateful for the opportunity to contribute to this consultation and recognises the importance of Open Space Strategies and Play Sufficiency Strategies in contributing towards key outcomes and multiple benefits including place-making, health and wellbeing, equalities, enhancing biodiversity, access and green networks, and climate change mitigation and adaptation. All of these are among key outcomes which East Lothian Council is already working towards.

An outcomes-based approach would enable us to align our OSS and PSA with other outcomes-based policies and strategies of the council, including but not limited to the East Lothian Plan, East Lothian Council Climate Change Strategy, East Lothian Poverty Plan, Local Housing Strategy.

As above. We are supportive of all of the proposed outcomes, which align with key outcomes which East Lothian Council is already working towards. However the outcomes need to be supported by indicators to measure how well they are achieved. The outcomes should also link to Community Planning outcomes and Scotland’s National Performance Framework National Outcomes.

Whilst ‘open space’ is defined as having a “civic function”, this definition is too vague and should specify “usable” open space. Cemeteries, allotment sites, SuDS ponds are all types of open space, however these are not ‘usable open space’ in the sense of fully accessible for public informal recreation. Clarity is required on the meaning of the term ‘open space’ in relation to its use. Not doing so risks developers bringing forward proposals for development sites that include SuDS, cemeteries, allotments within their ‘open space allocation’ – which would reduce the area available to the public for informal outdoor recreation in open and fully accessible green spaces.

In addition there is a need to define maximum distance from settlements, as “on the edge of settlements” is too vague.

The definition needs to be clear in order to clarify which areas of green space should be included in the OSS audit. For example, there may be areas of green space which do not have a “civic function” but which are still important to communities and to achieving the outcomes.

In addition, we would query whether beaches should be included as open space – particularly local beaches immediately adjacent to towns which form an important part of the town’s recreational space and which are usable and accessible (examples in East Lothian might include Fisherrow Beach at Musselburgh, North Berwick’s West and East Beaches, or Dunbar’s East Beach).

Green spaces do not only provide a recreational function, an amenity function, or aesthetic value to the public. They are also fundamental to nature, wildlife and enhancing biodiversity. They are also fundamental to climate change mitigation and adaptation. In a climate and nature emergency this must be acknowledged equally in addition to the benefits to people (these are not mutually exclusive), and must therefore be part of the definition of ‘green space’. The definition could therefore be linked back to the outcomes. “Green space” can also comprise of “green infrastructure” and if that is agreed then the proposed definition of “open space” would not require a further clarification that open space can form parts of green infrastructure e.g. a linear park may have a number of functions including ecosystem services functions.

It is also necessary to specify water, ideally in a separately defined category of ‘blue space’ which includes rivers, ponds, etc. which have important recreational and amenity functions, in addition to their functional and biodiversity importance. For example, in East Lothian the River Tyne and the Boating Pond at Levenhall lagoons, Musselburgh, are important for water-based recreation and as such form important aspects of our ‘open space’.

The definition of ‘green infrastructure’ should include that green infrastructure also provides Nature-based Solutions (NbS). NbS is not mentioned at all in the consultation paper. The definition could be expanded to include examples of what is meant by ‘green infrastructure’.

The definition of ‘green networks’ should also include ‘green space’. It might be useful to specify the functions of green networks. These generally include in particular recreation, biodiversity and active travel, however the outcomes here are wider.

This definition is too vague. Ecosystem services are context dependent, and underpinned by biodiversity. The definition could be expanded to include examples of what is meant by ‘ecosystem services’. Nature-based Solutions (NbS) (the tangible and intrinsic benefits provided by nature) are actions to maintain and enhance ecosystem services and it is important to include NbS in the definition.

The 0.2 ha threshold is appropriate; it is also helpful to be able to include other smaller spaces that are of benefit, should the local authority wish to include these.

Whether the open space area is located in / in close proximity to a SIMD area (e.g. 10% or 20% most deprived areas) should be included.

These are the same aspects as in our current Open Space Strategy so will enable comparisons to be made and consistency. An additional aspect to consider/assess could be ‘value’ of the open space; this would be separate to ‘quality’ as high quality open space could be poorly used and therefore of low value.

The consultation identifies women and people from ethnic minority groups as using open space less, so they could be specifically added to the consultees. This should include gypsy travellers.

This aspect is of crucial importance in strategic planning and future-proofing, particularly in relation to the growth agenda – East Lothian has one of the fastest growing populations in Scotland. This aspect of the OSS needs to set out the requirements for open space / green space to ensure that future developments adhere to these requirements as a minimum.

During the development of our strategies, East Lothian Council always seeks to engage with stakeholders including the general public, young people and other relevant groups/stakeholders, to seek their views and feedback and amend a draft strategy accordingly, and we agree with this as a way forward.

However a definition of ‘strategic green networks’ is required to clarify whether this means ‘green networks of open space’? Clarification is also needed of how this links with local authorities’ existing Green Networks Strategies, Biodiversity Action Plans, etc.

In our view these are fundamental aspects of what the Open Space Strategy must achieve.

As above.

As per question 2a above.

We agree it is important to give recognition to any suitable, accessible outdoor spaces that offer play opportunities for children.

However, the type of play will differ depending on the age, gender and abilities of the particular children.

The PSA should give greater recognition to play as a ‘state of being’ rather than only defining it in relation to a ‘space’. The PSA should recognise that the whole environment has a playscape dimension and consider how we can audit how children experience play, in order to fully understand all of the opportunities for play that an environment / local area may provide. We recognise that this approach was considered and rejected by the Working Group, however we feel that further consideration of how this could be recognised and incorporated in some way in the audit would be important.

We are supportive of assessing play opportunities in respect of age groups and we recognise the differing needs of different age groups. However, it will be difficult for local authorities to assess whether play spaces are suitable for ‘age 12 – 15’ compared with ’16 – 17’. Detailed guidance is required to assist with this aspect of the audit.

However, we believe it is important to also consider gender. Accessibility to open spaces, and feelings of safety and security in parks and open spaces, differ for males and females (particularly older children / teens); and the types of play may also differ for males and females. The group ‘Make Space for Girls’ sets out a good case for better consideration of the requirements for girls in open spaces / play areas to ensure inclusion, and this could also be a consideration in assessment of play sufficiency.

As above (Q14) ‘accessibility’ and inclusion should also take account of gender: different requirements that may be required by boys and girls in terms of play and access to play spaces / open spaces.

Provision of this information at locality level (in addition to local authority level) will enable identification of local areas requiring targeted improvements, which will be useful for strategic forward planning of play space improvements.

East Lothian Council already always consults with local children during the development / renewal of our play areas – we liaise with the local primary school(s), the pupils vote to choose their preferred design for the new play area, and this design is taken forward and implemented on the ground. We see this as a best practice model; and in addition we are currently working to further widen our consultation and engagement to ensure even better representation and inclusion going forward.

The list of consultees could include the need to consult specifically with girls, people from ethnic minority groups and disabled children to ensure their views are heard.

Additional comments:

Cultural and heritage benefits of open space - the link between open space and heritage is not explicitly mentioned in the regulations (other than by a reference to NPF4s 6 qualities of successful places [and that would be under no.4 Distinctive]) ; it may be worth emphasising that on-site and offsite heritage assets can play an important role in influencing the design of new open spaces.