RTPI Scotland's response to the Open Space Strategies and Play Sufficiency Assessments Consultation

Page 1 - Open Space Strategies

(a). Do you agree with the idea of promoting an outcomes-based approach through the Open Space Strategies Regulations?

Yes
No
No view

Any comments?

RTPI Scotland supports the promotion of the outcomes-based approach through the Open Space Strategies (OSS) Regulations.

RTPI Scotland wishes to see more detail on how the outcomes are to be monitored and wish to refer to recently published work we have published on the matter[1]. Our research aims to help provide practical ways to gauge how planning delivers on the explicit aspirations of planners and elected representatives, in terms of placemaking and social, economic and environmental value. The research report is accompanied by a suite of documents to deliver on the research aims. There is a Handbook that offers practical guidance, documents on the pilots carried out in Ireland and excel sheets providing the practical framework for implementing this new process of measurement. RTPI Scotland also wish to highlight the potential role for the new National Planning Improvement Coordinator here alongside an update of the National Greenspace Quality Guide.

As with a number of new and additional duties proposed in the draft Regulations, we are concerned over the resource burden, for example in this case of collecting and analysing data. This is especially true as many planning authorities currently don’t have the resource to build robust and extensive evidence bases which can be interpreted by GIS. Proposals need to take account of the context of diminishing resources and increased workloads in planning authorities with recent research from RTPI Scotland^[2] showing that:

Nearly a third of planning department staff have been cut since 2009
Planning authorities’ budgets have diminished in real terms by 42% since 2009
In 2020 local authorities only spent 0.38% of their total net revenue budgets
Planning application fees only cover 66% of their processing costs
There are 91 new and unfunded duties in the Planning (Scotland) Act, which could cost between £12.1m and £59.1m over 10 years
Over the next 10 to 15 years there will be a demand for an additional 680 to 730 entrants into the sector

Whilst we welcome the increase in planning fees to bring much needed resource into the system, as set out in recently published research^[3] we do not believe this will guarantee the adequate resources for the planning service to undertake its statutory duties. We are particularly concerned that if the increased fee income is reinvested back into the planning service, it will predominantly be reinvested into the development management service, thereby creating specific resourcing issues for development planning teams which will prepare OSSs and Play Sufficiency Assessments (PSAs). RTPI Scotland see clear role for the Scottish Government’s Digital Planning Taskforce to make the process user friendly, efficacious, and robust regarding the collection and collating of data to inform OSSs.

RTPI Scotland notes reference in the consultation document to our cost estimates for these additional and unfunded duties following Royal Assent of the Planning (Scotland) Act 2019. Having considered the content of the Regulations we believe this previous estimate to be a considerable underestimate which will need updated. We would be happy to discuss this with Scottish Government.

(b). Do you agree with the suggested outcomes?

Yes
No
No view

Any comments?

RTPI Scotland is broadly supportive of the suggested outcomes but believe that better connection need made to outcomes and the policy ambitions set out in the draft NPF4. In particular, this includes setting out the role that OSSs could have in tackling Vacant and Derelict land, with the delivery of urban greenspace considered a relatively quick and low-cost approach for addressing problematic sites[4]. RTPI Scotland also wish to see fuller consideration of how OSSs are to align with the NPF4 in regards to the 6 qualities of successful places, the Infrastructure First principle and support the move towards more city centre living.

Do you agree with the proposed definition of:

(a) ‘open space’

Yes
No
No view

(b) ’green space’

Yes
No
No view

(c) ‘green infrastructure’

Yes
No
No view

(d) ‘green networks’

Yes
No
No view

(e) ‘ecosystem services’

Yes
No
No view

‘open space’ definition - Any comments?

RTPI Scotland believes more clarity can be achieved in this definition with green, blue and grey space set out as defined subsets of open space, each with its own definition. The use of diagrams may provide support the user in understanding the relationship between open space types.

’green space’ definition - Any comments?

RTPI Scotland believes that allotments should be included in a green space definition and that water bodies be set out separately in a blue space definition.

‘green infrastructure’ definition - Any comments?

RTPI Scotland wish to see alignment with the definition as set out by NatureScot.

'green networks’ definition - Any comments?

See answer to 2(a) regarding open space definition.

RTPI Scotland wishes to highlight concerns expressed in response to both the draft NPF4 and draft LDP guidance and regulations over the use of ambiguous related terms such as nature networks. We believe that clear definitions need to be set out across the documents and then carefully aligned.

'ecosystem services’ definition - Any comments?

RTPI Scotland wishes to see alignment with the definition as set out by NatureScot.

Do you agree with proposed thresholds for open space audits in Draft Regulation 4(2)?

Yes
No
No view

Any comments?

RTPI Scotland broadly agrees with the thresholds set out in the draft Regulations.

(a). Do you agree with suggested information to include about each open space (location, size and type)?

Yes
No
No view

Any comments?

RTPI Scotland supports the suggested information and support having open digital mapping available, again highlighting the role of the Scottish Government’s Digital Taskforce on the matter.

(b). Do you agree with Regulation 4(5) on the other information planning authorities may include in the audit?

Yes
No
No view

Any comments?

RTPI Scotland broadly agrees with the Regulation 4(5) although wish to again stress concerns over the resourcing requirements of the data collection and analysis.

(a). Do you agree with the suggested approach to require locality level place-based information?

Yes
No
No view

Any comments?

RTPI Scotland believes the approach set out to require locality level place-based information to be correct.

(b). Do you agree with the three high level aspects that should be covered in these statements ‘accessibility’, ‘quantity’ and ‘quality’?

Yes
No
No view

Any comments?

RTPI Scotland broadly supports the statements on three high level aspects of accessibility, quantity and quality. We do however note a number of points including:

RTPI Scotland wishes to again stress concerns over the resourcing requirements of the data collection and analysis.
The term blue space is used without a definition provided elsewhere - see answer to Q2(a)
Clearer links need made with outcomes and policy ambitions in the NPF4 - see answer to Q1(b)

Do you agree with the list of consultees for the open space audit?

Yes
No
No view

Any comments?

RTPI Scotland supports this list of consultees on an OSS but are concerned over the resourcing implications of doing so. RTPI Scotland believe that the guidance should demonstrate how the consultation process can be combined with other engagement activities around in for example, the Local Development Plan and Local Place Plan preparation.

(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?

Yes
No
No view

Any comments?

RTPI Scotland support this approach, notwithstanding comments on the outcomes in response to Q1(b).

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?

Yes
No
No view

Any comments?

RTPI Scotland supports the proposed provisions although wish to reiterate comments made in response Q6 regarding resourcing concerns and looking for opportunities to join up engagement activities.

(a). Do you agree Open Space Strategies should include a statement setting out how they contribute to the outcomes?

Yes
No
No view

Any comments?

RTPI Scotland supports the inclusion of such a statement. Additional guidance on how alignment of OSS can be made with documents such as Forestry and Woodland Strategies would be beneficial. RTPI Scotland would again like to highlight that many planning authorities currently don’t have the resource and in-house capacity to undertake advanced GIS work.

8.(b). Do you agree Open Space Strategies should identify strategic green networks?

Yes
No
No view

Any comments?

No further comment.

8.(c). Do you agree Open Space Strategies should identify how green networks may be enhanced?

Yes
No
No view

Any comments?

No further comment.

Do you agree with the proposed consultation requirements on draft Open Space Strategies?

Yes
No
No view

Any comments?

No further comment.

Do you agree with the proposed publication requirements for Open Space Strategies?

Yes
No
No view

Any comments?

No comment.

Do you agree the Regulations should set a 10 year minimum review period for updating open space audits and strategies?

Yes
No
No view

Any comments?

RTPI Scotland supports the alignment with the new proposed 10 year cycle for LDPs.

Page 2 - Play Sufficiency Assessments

Do you agree with the proposed definitions?

“children"
Yes
No
No view
“localities”
Yes
No
No view.
“open space”
Yes
No
No view
“play spaces”
Yes
No
No view

Further clarity on sites which may be used by children for play opportunities but have other uses, such as skateparks, would be welcomed.

“children" definition - Any comments?
“localities” definition - Any comments?
“open space” definition - Any comments?

Please see response to Q2(a)

“play spaces” definition - Any comments?

Do you agree planning authorities should map the locations of the two categories of play spaces, and how they are described in Draft Regulations 3(2)(a) and (b)?

Yes
No
No view

Any comments?

RTPI Scotland supports the principle of mapping sites for play although are concerned about the practicalities and resourcing requirements of doing so in regards to regulation 3(2)(b).

Do you agree with the proposed requirement to assess play opportunities in respect of their suitability by age groups?

Yes
No
No view

Any comments?

RTPI Scotland broadly supports the requirements to assess play opportunities in respect of their suitability by age groups.

(a). Do you agree with the proposed three aspects of assessment - ‘accessibility’, ‘quantity’ and ‘quality’?

Yes
No
No view

Any comments?

RTPI Scotland broadly agrees with the proposed three aspects of assessment although we wish to again highlight concerns over the resourcing impact of collecting and analysing data. We also note some lack of consistency between OSS and PSA regarding accessibility.

(b). Do you agree to provide them in written statements in respect of the totality of the local authority area and at each locality level?

Yes
No
No view

Any comments?

RTPI Scotland supports this requirement but are concerned over the additional resourcing burdens.

(a). Do you agree to the requirement to consult as part of the process of carrying out the play sufficiency assessment?

Yes
No
No view

Any comments?

RTPI Scotland agrees with the requirement to consult on PSAs although are concerned over resourcing. We would advocate for the exploration of opportunities to join up engagement activities.

16.(b). Do you agree with the proposed list of consultees on play sufficiency assessments?

Yes
No
No view

Any comments?

No comment.

Do you agree with the publication requirement for play sufficiency assessments?

Yes
No
No view

Any comments?

RTPI Scotland wishes to see clear alignment between the publication of PSAs and LDP evidence reports.

Page 3 - Impact Assessments

Do you have or can you direct us to any additional information that would assist in finalising these assessments (BRIA, EQIA, CRWIA, ICIA)?

As mentioned in Q1(a), given consideration of the content of the proposed Regulations on OSS and PSAs, RTPI Scotland believes that our previous estimation are now an underestimate and would encourage a fresh look at resourcing requirements of the proposed Regulations on planning authorities. We are happy to work with HOPS and Scottish Government to establish a more accurate estimate of costings.

Please give us your views on the content of these assessments and how they have informed the draft provisions, or if you think changes are needed to the Regulations to further respond to the issues?

No comment.

Do you agree with the Fairer Scotland Duty screening and our conclusion that full assessment is not required.

Yes

Do you agree with the Strategic Environmental Assessment pre-screenings, that the Open Space Strategies and Play Sufficiency Assessments Regulations are exempt from the Environmental Assessment (Scotland) Act 2005, as the environmental effects are likely to be minimal?