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Specific Research Findings
Title
12. The title of the document has been changed to: Scottish Planning Policy 11: Open Space and Physical Activity to better reflect the emphasis on open space as a key resource supporting physical activity.
Summary and Introduction
13. A large majority of respondents agreed with the principles, objectives and main proposals contained in draft SPP 11. However, several suggested that more comprehensive definitions of 'Open Space' and 'Physical Activity' should be provided in order to clarify what is covered by the SPP.
Response:
14. The key objectives have altered as a result of various changes from the consultation draft, and more comprehensive definitions of 'open space', 'physical activity' and 'recreation' are included in Paragraph 2. The use of these terms has been made more consistent throughout the document.
The value of open space for outdoor recreation & physical activity and policy context
15. The summary of the value of physical activity and open space, and the policy context that forms the background to the draft SPP, were welcomed. In particular, there was strong support from allotments societies and several individuals for the reference to allotments.
Response:
16. The title of this section has been changed to reflect the title of the SPP. Changes have been made to the text, and the health benefits of physical activity and environmental benefits of open space given greater emphasis.
SPP Objectives
17. The SPP's objectives were overwhelmingly supported by respondents from all sectors. However, private sector organisations and a small number of local authorities criticised the draft SPP's 'over presumption' against the loss of open space.
Response:
18. The first objective has been expanded to state briefly the role of local authorities in undertaking audits for their open space strategy. The words 'networks of' have been removed from the second objective because open spaces which are not part of a network will also be protected. This objective now appears first in the final SPP, to reflect its importance. The third objective has been strengthened. The fourth objective now relates to guidance on the quality and accessibility of open space, and reflects the omission of the proposed national minimum quantitative standards on open space from the final SPP.
RAISING STANDARDS
Quality, Quantity and Accessibility (paragraphs 20-21, new paragraphs 34-39)
19. Concern was expressed by some respondents that the SPP does not meet its aim of providing standards for quality and accessibility. It was suggested amongst the responses that there should be minimum standards as the SPP does not set the practical definitive standards for quality as it prescribes to do in its initial objectives.
Response:
20. This section has been expanded in response to these suggestions, although the objective of the SPP is now to provide guidance on, rather than standards for, quality and accessibility. There is now a list of factors relating to the quality of open space, particularly covering design and access. There is now greater emphasis on accessibility.
Open Space Audit and Strategy (paragraphs 22-27, new paragraphs 23-33)
21. Respondents from all sectors expressed strong support for the proposal that local authorities should prepare an open space audit and strategy. Some comments were made on the broadening of the categories in PAN 65 to cover, for example, allotments and community gardens. Several also suggested that the requirement for audits and strategies would be strengthened if there was a required timeframe for their preparation, e.g. within two years of the publication of the SPP. Around half of the local authorities that responded raised concerns about the resource implications of preparing audits.
Response:
22. This section has been placed before the section on 'Quality, Quantity and Accessibility' to improve the flow of the document. We have considered the issue of an initial timeframe for the preparation of all audits and strategies. We have adjusted the SPP to make it clear that all local authorities should start now to ensure that an audit and strategy is prepared for their areas and that they should be updated on a regular 5 year cycle. The SPP fits the strategies into the development plan and there is a statutory requirement for preparing and updating development plans. We believe this is sufficient. A number of authorities have already embarked on preparing audits and strategies and are able to do so within their existing resources. We have also said that local authorities should consider whether some of the PAN 65 categories require further classification.
PROTECTION OF OPEN SPACE
Presumption against development of open space (paragraphs 28-35, new paragraphs 40-56)
23. Most respondents were strongly supportive of the draft SPP's presumption against the development of existing open space and several suggestions were made for strengthening the policy. However, some private sector organisations and several local authorities criticised the proposal for being too broad and vague. There were few objections to the proposal to broaden sportscotland's remit as a statutory consultee to include smaller scale/community sports facilities and demolition of sports facilities.
Response:
24. The list of community sports facilities at old paragraph 35 (now 56) is amended following agreement with sportscotland. This does not now include demolition. Although this had received broad support, we do not consider that there is a strong argument for introducing controls over demolition. If a facility operator is minded to close a facility, this can be done and would not be prevented by controls over demolition.
25. New paragraph 40 expands on the original text in identifying that there is a presumption against development of open space which has been identified in the development plan as having a future role for open space as well as a community need. Development plans will identify such open spaces, in line with the findings of the open space audit and strategy. Smaller areas of valued open space, even if not identified in the strategy, should also be protected through development plan policies.
26. New paragraph 41 expands on issues covering replacing or redeveloping open spaces to ensure that appropriate replacement facilities are provided and that levels of open space in an area should not be reduced unless there is a clearly identified existing surplus.
Local Authority Development and Schools Development (paragraphs 26-39, new paragraphs 49-53)
27. Respondents were generally supportive of the proposals here, although several suggested that amendments are required to take account of the wider role of open space in schools beyond providing sports pitches.
Response:
28. This section now makes reference to the recent Planning Advice Note on the handling of planning applications where local authorities have interest in the proposed development. Paragraph 50 expands upon the variety of roles open space plays in schools.
PLANNING FOR OPEN SPACE WITHIN NEW DEVELOPMENT
Minimum Standards (paragraphs 42-44, new paragraphs 57-60)
29. Many respondents raised concerns over the proposed national minimum standards. Just over half gave qualified support whilst almost one-fifth did not support the proposed standards. Private sector organisations expressed the following concerns:
- minimum standards could become the norm,
- the SPP proposes minimum standards for quantity of open space but not for quality,
- the proposed standards do not cover accessibility,
- the proposed standards for Class 9 (residential) do not allow for flexibility to take account of household size and different types of development. There was also concern expressed about scope for affordable housing and regeneration developments.
Response:
30. Following public responses, additional consultation with the stakeholder group and further consideration by Ministers, these paragraphs have been completely revised and the proposed national minimum standards for open space in new development have been omitted. Ministers share concerns that the inflexibility of national minimum standards would mean no account could be taken of local circumstances such as the existence of nearby open space and the difference between urban and rural settings. Concerns that minimum standards could place an additional burden threatening some regeneration, brownfield and affordable housing developments are also considered to be valid.
31. The document now states that local authorities, rather than apply national minimum standards, should ensure that new development is appropriately served by open space, with any requirements set out in the development plan, as informed by the local open space audit and strategy. In addition, the paragraphs on management and maintenance have been moved to this section and strengthened to reflect recent public concerns on the management of common open space in residential areas. Paragraphs 57-60 (and their accompanying text boxes) may now be summarised as follows:
- Planning authorities should, having regard to the findings of their open space audit and strategy, set out in local development plans specific requirements for the provision of open space in new developments.
- The audit and strategy may highlight differing priorities for a number of settlements or neighbourhoods and any such differences should be reflected in the development plan.
- Where developer contributions of open space are to be sought, it is important that the plan makes clear how much, of what type and quality, and what the accessibility requirements are.
- A flexible approach should be adopted when seeking open space contributions from new developments, taking into account other material considerations and priorities. Development plans should set out a sequential approach to open space delivery, informed by the priorities in the open space strategy.
- Where the open space strategy indicates a surplus in the quantity of open space in the local area, a financial contribution towards the improvement or management of existing open space may be an acceptable alternative to the provision of open space as part of the development.
- Where the open space strategy indicates deficiencies of open space in the local area, providing open space as part of the development will often be the preferred approach.
- Development plans, or where more appropriate masterplans or site briefs, should adopt a strategic approach to identifying areas of open space in new development or redevelopment. This planned approach may produce better layouts than the incremental provision of small pockets of open space in line with planning application and land ownership boundaries.
PLANNING FOR NEW FACILITIES FOR SPORT AND RECREATION (paragraphs 48-54, new paragraphs 65-71)
32. Most respondents that commented here were supportive, but several sought to strengthen or clarify various aspects such as the scope of the Land Reform Act, development on the edge of settlements, green belt development and stadia.
Response:
33. The title of this section has been changed to 'Planning for Sport and Recreation' as advice is now given on impacts on existing facilities and resources. Additional changes to the text have been incorporated following further discussion with sportscotland, in particular in relation to resources for sport in the outdoors.
OUTDOOR ACCESS AND RECREATION (paragraphs 55-60, new paragraphs 18-22)
34. Respondents who supported the proposals in this section also made comments directed at strengthening aspects of the proposals on National Parks and Core Paths Plans.
Response:
35. This section has been moved to improve the flow of the document, and various changes made following further consultation with the stakeholder group. Some detail has been omitted or moved elsewhere, but the broad objectives of this section remain the same.
IMPLEMENTATION (paragraphs 61-68, new paragraphs 72-79)
36. This section summarises the key responsibilities of local authorities, communities and developers in relation to open space. Various, relatively minor, changes have been made and the paragraphs re-ordered.
GLOSSARY AND INFORMATION ON CONSULTEES AND STAKEHOLDERS
37. There were some changes and additions made to these sections.
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