Open Space Strategies and Play Sufficiency Assessments

Yes, although it would be good if there were a way to meaningfully measure success in the delivery of these outcomes. The proposed update to the national Greenspace Quality Guide would represent a good opportunity to do this, however it would be important that any new approach to measurement are backwards compatible with the current system of monitoring.

Yes, however, a more explicit reference to creating attractive environments would be welcomed. The closest the present outcomes come to this is a reference to successful places, but it might not be evident to everyone this should includes creating attractive places. Attractive places are important to encourage use of open spaces and, in turn, help with delivery of many of the other outcomes listed.

Inclusivity should also be stated alongside accessibility in the title of the outcome relating to accessibility. Although the consultation paper does explain that improving inclusivity is part of assessing accessibility (as shown in the table below para. 46), it would help to highlight the importance of inclusivity for it to be noted in the title of outcome itself.

No. The definition of open space is linked to the definition of greenspace and there are concerns with that definition (see answer to question 2b below).

No. This definition does not include horticulture. Horticultural areas can be an important form of open space in urban areas, including allotments and community growing areas. Horticulture should not be included in the exclusion at the end of the definition set out in the draft regulations.

e) ‘ecosystem services’
Yes, although it would help to list in guidance some of the main examples of the benefits that can be derived from ecosystem services.

Yes. Guidance however should be make it clear that LPAs have discretion in how they structure their audit in relation to how it groups different sizes and types of spaces. It is inferred from legislation that this is the case, however confirmation would be welcomed.

More discretion over the maximum size of population that can be considered to exist in a single neighbourhood would be welcomed, however it is appreciate that the definition of localities comes from existing legislation and so redressing this would require a breaking from an established definition and may present issues of inconsistency.

Overall yes, however there is reference to issues of maintenance. It is proposed that OSSs should consider issues of maintenance. Local planning authorities often cannot enforce existing or proposed maintenance arrangements however. There would consequently be misleading impression given of local planning authority powers. It may also result in OSSs setting out proposals that cannot be implemented.

Yes, although it should be made clear that OSSs and PSAs can make reference to other related strategies where these set out further details on how these outcomes are addressed; for example Forestry and Woodland Strategies.

The reference to a minimum review period in this question and the consultation paper is confusing. It would be clearer if it was stated that 10 years is the maximum period of time which can elapse between the production of new OSSs so as to reflect the wording of the draft legislation itself which is appropriate in this regard.

Notwithstanding this, there is no objection to the 10 years period but only on the condition there is the option for interim updates to particular parts of OSSs, PSAs and/or associated audits. This would ensure they remain fit for purpose. In particular this would assist monitoring and evaluation of the standard of open spaces and green networks. It would also allow new greenspace proposals to be added as they emerge and for the status of existing proposals can be updated as they go through the different stages of design and delivery.

Up to date information on proposals is important in ensuring cross-linkages with other strategies such as local development plans, as well as ensuring new developments deliver and contribute to greenspace proposals where appropriate through the development management process. This would support the aspiration in the consultation paper that OSSs and PSAs should link to planning, but would ensure this happens through the development management process as well as local development plans.

See response to question 5a

No. See response to question 2a.

Yes, although it could be expanded to be explicit about whether facilities such as Multi Use Games Areas and Skateparks are considered part of this definition or whether they are classed as sports areas. The definition of sports areas does not explicitly say whether it includes these types of facilities either, although it does say sports facilities are generally those which have to be booked which means– in the absence of explicit confirmation – sports facilities does not cover MUGAs and skateparks. To avoid ambiguity however clarification would be helpful.

No

No changes needed

Suggest updating statement to say 'There should be minimal negative impacts. '

No