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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1. (b). Do you agree with the suggested outcomes?
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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: Checked No | (a) ‘open space’ No view Radio button: Not 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: Checked Yes | (d) 'green networks’ No Radio button: Not 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 |
(a) ‘open space’ definition - Any comments?
Open Space definition. As worded, this wouldn’t include those sports areas that are not grass (grass sports areas are covered in the green space definition). This issue will apply mainly to synthetic pitches and tennis courts. While these wouldn’t fall within the definition of ‘green space’, they are a valuable part of an area’s open space and contribute to the outcomes identified in the consultation. We suggest the definition of open space is amended to ensure these spaces are included, we have suggested 2 options below as a way of addressing this:
“open space” means space within and on the edge of settlements comprising; green space; or civic areas such as squares, market places and other paved or hard landscaped areas with a civic function or synthetic surfaced outdoor sports facilities.
“open space” means space within and on the edge of settlements comprising; green space; civic or leisure, sport and play areas such as squares, market places and other paved or hard landscaped areas with a civic, leisure, sport and play function.
There is a need to include a definition of outdoor sports facilities and would suggest including the existing one from the relevant legislation.
“open space” means space within and on the edge of settlements comprising; green space; or civic areas such as squares, market places and other paved or hard landscaped areas with a civic function or synthetic surfaced outdoor sports facilities.
“open space” means space within and on the edge of settlements comprising; green space; civic or leisure, sport and play areas such as squares, market places and other paved or hard landscaped areas with a civic, leisure, sport and play function.
There is a need to include a definition of outdoor sports facilities and would suggest including the existing one from the relevant legislation.
3. Do you agree with proposed thresholds for open space audits in Draft Regulation 4(2)?
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4. (a). Do you agree with suggested information to include about each open space (location, size and type)?
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Any comments?
The definition of sports areas is given as - Large and generally flat areas of grassland or specially designed surfaces, used primarily for designated sports (including playing fields, golf courses, tennis courts and bowling greens) and which are generally bookable.
Suggested change – is ‘generally bookable’ required? Not all spaces will fall under this definition and we don’t think it’s needed in relation to the definition. Appreciate the proposed wording has been carried over from the PAN65 definition.
Suggested change – is ‘generally bookable’ required? Not all spaces will fall under this definition and we don’t think it’s needed in relation to the definition. Appreciate the proposed wording has been carried over from the PAN65 definition.
4. (b). Do you agree with Regulation 4(5) on the other information planning authorities may include in the audit?
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Any comments?
This is a more general comment about how places for sport will be considered in OSS. Generally, these have included information on places for sport at a high level, without detail on outdoor sports facilities. This is the case as to do so requires consultation with the various sports users as well as detailed supply and demand information for the different types (such as bowling greens, tennis courts, pitches – which themselves will serve a variety of sports).
As such, when done, they tend to be stand alone documents. Our experience is also that there are not many up to date pitch strategies, largely in our view due to resource challenges for councils in delivering these. While we welcome the requirement generally to undertake OSS, we are not clear about how these are intended to cover demand led spaces like outdoor sports facilities. The guidance as worded, while very helpful for OSS generally, doesn’t give a steer on the strategic approach to be taken for outdoor sports facilities.
If the intention is that an OSS is to cover the demand led open space types such as outdoor sports facilities, there should be some recognition in the guidance that the methodology to be used needs to be altered accordingly to cover these uses. Or if the intention is that the OSS considers these are a high level, with more detailed work sitting separate to the over-arching OSS, then this should also be clarified in the guidance. If it is not our concern is that there could be confusion going forward in relation to what is required in relation to these spaces.
In conclusion, our view is that there should be text which recognises while OSS can consider outdoor sports facilities at a high level as part of an area’s open space, but to adequately plan for them, more detailed and demand led work is needed.
As such, when done, they tend to be stand alone documents. Our experience is also that there are not many up to date pitch strategies, largely in our view due to resource challenges for councils in delivering these. While we welcome the requirement generally to undertake OSS, we are not clear about how these are intended to cover demand led spaces like outdoor sports facilities. The guidance as worded, while very helpful for OSS generally, doesn’t give a steer on the strategic approach to be taken for outdoor sports facilities.
If the intention is that an OSS is to cover the demand led open space types such as outdoor sports facilities, there should be some recognition in the guidance that the methodology to be used needs to be altered accordingly to cover these uses. Or if the intention is that the OSS considers these are a high level, with more detailed work sitting separate to the over-arching OSS, then this should also be clarified in the guidance. If it is not our concern is that there could be confusion going forward in relation to what is required in relation to these spaces.
In conclusion, our view is that there should be text which recognises while OSS can consider outdoor sports facilities at a high level as part of an area’s open space, but to adequately plan for them, more detailed and demand led work is needed.
5. (a). Do you agree with the suggested approach to require locality level place-based information?
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Any comments?
In relation to demand led open spaces like sports facilities, it should be recognised that localities may vary. But taking a locality approach generally is one we support and is a good way of flagging where there are gaps in different types of open space provision.
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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Any comments?
But as noted under question 4b above, these aspects would be considered differently for demand led open space types such as sports facilities.
6. Do you agree with the list of consultees for the open space audit?
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Any comments?
For demand led spaces - engagement with relevant groups, we think this should this be specified here in relation to demand led spaces.
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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Any comments?
Please see comments in relation to question 4b.
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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8. (a). Do you agree Open Space Strategies should include a statement setting out how they contribute to the outcomes?
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8. (b). Do you agree Open Space Strategies should identify strategic green networks?
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8. (c). Do you agree Open Space Strategies should identify how green networks may be enhanced?
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9. Do you agree with the proposed consultation requirements on draft Open Space Strategies?
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Any comments?
Our view is that getting the engagement right (covered under question 7), will be key to getting any draft strategy fit for purpose. So building in the time at engagement stage will be of greater value than when the draft strategy is published for consultation.
10. Do you agree with the proposed publication requirements for Open Space Strategies?
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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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