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Questions posed to consultees in draft SPP
Consultation Question (i)
We propose that the audit and strategy should be updated at least every 5 years to inform the review of the development plan. Comments are invited on this proposed timescale for updating of the audit and strategy. Do you consider that there is a need for annual monitoring of changes in local provision of green/open space?
38. Over 90% of respondents that answered supported the proposal that open space audits and strategies should be updated at least every five years and around three quarters agreed that there should be annual monitoring of audits. Qualifications centred around three main issues: resources, scale/threshold of community or area to be covered by the audit, and timescale. See paragraph 22 above for response.
Consultation Question (ii)
Do you agree that the SPP should include a model development plan policy for protection of open space?
39. Whilst over 90% of respondents supported the principle of a model policy for protection of open space, there was no consensus as to whether it should be mandatory. Few respondents agreed with the wording of the draft provided in the SPP. Most suggested that there needs to be flexibility to allow for local circumstances.
Response
40. The reason for a model policy is to provide a consistent approach around the country, and the lack of consensus on this issue undermines the case for such a policy. This proposal has therefore been omitted, although the policy advice dealing specifically with the protection of playing fields is noted in the document as a potential model policy.
Consultation Question (iii)
For development proposals likely to affect other types of open space not included in the remit of sportscotland, is there a need for further consultation arrangements, for example with Scottish Natural Heritage or Greenspace Scotland?
41. Whilst there was general support for the principle of extending consultation on development proposals, there was little support for the proposal to include Scottish Natural Heritage and Greenspace Scotland, including from the organisations themselves. A significant minority supported the view that local authorities are best placed to consider development proposals in consultation with the community.
42. Several local authorities and private sector organisations expressed concern over development of land identified as open space being notified to Ministers, and that extending consultation on certain matters to sportscotland and other national agencies might slow down the planning process.
Response
43. This proposal has not been retained. There is no suitable organisation at present to fulfil this role. Given that the SPP requires open space strategies to be undertaken in every local authority, extends sportscotland's consultation role, and introduces new notification procedures for developments proposing the loss of protected open spaces, Ministers do not consider that there is a strong case for introducing any wider consultation arrangements. The SPP encourages local authorities to consult relevant local and national interests where appropriate for particular development proposals.
Consultation Question (iv)
Should controls extend to demolition of facilities, to avoid the potential for removal of sports facilities without consultation with sportscotland?
44. Eighty percent of respondents supported the proposal to extend controls to the demolition of facilities. Over half of these qualified their support, mainly raising queries about the definition/scope of the term 'sports facilities'. See paragraph 24 above for response.
Consultation Question (v)
Do you consider the proposed standards and thresholds to be appropriate? Are there other types of development that you consider should be included in the standards?
45. Less than one-fifth of respondents gave the proposed national minimum standards unqualified support. Just over half gave qualified support whilst almost one-fifth did not support the proposed standards. Private sector organisations were particularly critical. Concerns included:
- 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.
46. Suggestions for other types of development to be included within the national minimum open space standards for new development included: nursing and residential homes, hospitals, and medical centres; hotels and tourist developments; and schools and further education establishments. The proposed minimum standards have been omitted. See paragraphs 30 and 31 above for response.
Consultation Question (vi)
Should there be a different set of minimum standards for the quantity of open space required in developments in rural areas? Do you have views on appropriate thresholds and quantities?
47. Although there was general acceptance that rural areas might have different needs and priorities, there was no consensus on whether there should be different national minimum standards for rural areas.
Response
48. The proposed minimum standards have been omitted. Paragraph 57 the final SPP states that the strategy and development plan should reflect any differences in requirements between communities, and this will allow for differing approaches to rural and urban provision where this is appropriate.
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