Scottish Government

7. Raising Standards (paragraphs 20 - 27)
Consultation Question (i)

7.1 The consultation responses almost unanimously supported the proposal that local authorities should prepare an open space audit and strategy. Respondents from all sectors expressed strong support for the principle behind open space audits and strategies. For example, the British Property Foundation welcomed the aim of the SPP to ensure local authorities take a long-term approach to managing the open space within their areas and further stated: " The requirement that all local authorities will have to carry out an open space audit and prepare an open space strategy is a positive method of delivering this and will allow developers to make informed commercial judgements about the open space requirements related to specific developments at an early stage."

7.2 Several respondents commented on the process for undertaking open space audits and strategies as outlined in paragraphs 22 - 27. These included suggestions that the scope of the audit or classifications/ typology used should be clarified or expanded; for example, referring specifically to 'vacant and derelict land' (Scottish Natural Heritage), play areas and allotments (City of Edinburgh Council). The Scottish Allotments and Garden Society supported by individual respondents and other organisations such as the Federation of City Farms and Community Gardens suggested that the reference to allotments and gardens in the last sentence of paragraph 23 should be strengthened to read ' in all urban and rural areas it is appropriate to include allotments and…'

7.3 Several respondents suggested that local authorities have made slow progress in completing open space audits since the publication of PAN 65 in January 2003. One response included the results of a survey undertaken on behalf of the Holmhills Community Park Action Group that suggests that by April 2006 less than a quarter of Scottish councils had completed and published an open space audit and less than a third had actually begun undertaking an audit.

7.4 The Royal Town Planning Institute was one of several respondents that suggested that a timescale should be set for the preparation of open space audits and adopting strategies. It suggested that the statement in paragraph 23 which reads: 'an early start should be made to prepare audits and strategies in those areas that have not already done so', is too vague and that the Scottish Government should set a clear timetable for the starting and completing of audits and strategies by including the following amendment to the draft SPP: " Open space audits and strategies to be completed within two years of the date of publication of SPP11; Audits to be updated on an annual basis, as is the case with the Active Places database in England."

7.5 The reference in paragraph 24 to ensuring 'members of the community have full opportunity to provide input during the audit' was strongly welcomed, particularly by community organisations. However, several Community Councils suggested that this section of the SPP could be strengthened by including specific reference to Community Councils. Helensburgh Community Council provided a detailed suggestion for Community Council involvement, including the sub-dividing of the audit into community council areas.

7.6 Several respondents including the Royal Town Planning Institute and Scottish Natural Heritage suggested that the reference to linking the open space strategy into the Community Planning framework could be strengthened. City of Edinburgh Council went further and suggested that the Community Planning Partnership could have a formal role in drawing up the strategy.

7.7 A key issue raised by 13 of the 28 planning authorities that responded to the consultation was that additional resources might be required to undertake, prepare and monitor open space audits and strategies. For example, Renfrewshire Council's response states: "the provisions of the SPP inevitably will involve local authorities in additional work, and there is a concern that no reference is made in the guidelines to the implications for councils' resources, in terms of their ability to meet the targets for preparation, monitoring and reviewing of audits and strategies."

7.8 Dumfries and Galloway Council stated: "Resources to undertake open space audits/strategies will need to be made available during the financial year 2007/08 and in subsequent years as required. In 2005 (Dumfries and Galloway Council) Leisure and Sport undertook an assessment of sports pitches at a cost of £25,000. The scope of the audit as required by the guidance is likely to be much more extensive."

7.9 The complexity of undertaking an open space audit and preparing a strategy was commented on by several councils and other respondents. For example, Kit Campbell Associates who have extensive experience of working in this area, suggested that "the SPP should not simply require councils to prepare strategies, but (should) also indicate that they are major pieces of work."

7.10 The Holmhills Wood Community Park Action Group review of open space audits and strategies suggested that West Lothian Council's approach provides a good example of how strategies might be developed. West Lothian Council's Open Space Strategy (April 2005) involved creating a detailed audit and access database covering publicly accessible parks and open spaces, amenity open spaces, green corridors, natural/ semi-natural greenspaces and other functional greenspaces. Based on extensive consultations the strategy also put forward a strategy and toolkit for managing the open space on a settlement-by-settlement basis with practical recommendations for each area. ⁵

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?

7.11 The analysis of Question (i) splits responses into (a) whether open space audits and strategies should be updated at least every 5 years; and (b) whether there is a need for annual monitoring.

7.12 Over 90% of the respondents that answered Question (ia) supported the proposal that local authorities must prepare an open space audit and strategy that should be updated ' at least every 5 years'. However, a significant minority of respondents, including 20 local authorities and five national organisations qualified their support. (Diagram 3 and Table Qi(a), Appendix 3)

Diagram 3: Responses to Question (i.a)

Base: 79 responses

7.13 There was a high level of support for the proposal to have annual monitoring; although again this support was largely qualified; a quarter of respondents who answered this part of Question (i) gave the proposal unqualified support whereas just under 50% gave it qualified support. Around 13% of respondents answered this question with a no or qualified no. (Diagram 4 and Table Qi(b), Appendix 3)

Diagram 4: Responses to Question (i.b)

Base: 79 responses

7.14 The qualifications to support the updating of audits and strategies at least every 5 years with annual monitoring revolved around the following three key issues:

Resources

As highlighted above, a significant minority of councils commented on the resource implications of carrying out open space audits and preparing strategies.

Scale/thresholds

Several councils commented on the need for guidance on the scale of community or area to be covered by the open space audit. For example Highland Council made the point that for small rural settlements 'The task of preparing an audit of all these areas is considered to be excessive, particularly without additional funding to carry out the work. The SPP should set out a population threshold (5000) for which audits must be undertaken…The qualitative and quantitative needs for open space provision in smaller settlements must therefore be dealt with within the review of local development plans."

West Dunbartonshire Council's response stated: "The SPP indicates that an open Space Audit be carried out for all the open spaces included in the PAN 65 typology. There is no minimum size of open space given for such an audit, although 0.2ha appears to be the usual minimum size used by local authorities undertaking recent audits, following SNH advice. It is recognised that functional uses of existing open space may include sites below 0.2ha therefore criteria for choosing open spaces below would be required. It would therefore be appropriate to indicate the minimum size of site for the open space audit and a set of criteria for surveying sites below that size."

Timescale for monitoring and reviewing audits and strategies

Several respondents suggested that the five year timeframe proposed in the draft SPP might be too long a period between reviews. For example, Homes for Scotland stated: "Five years is too long a period in which to rely on information about surpluses and deficits of provision which will be used to assess planning applications. Other planning matters, such as land supply for housing and employment, or sustainability indicators, are monitored annually and there should be no difference in the case of open space provision."

Other respondents suggested that annual monitoring might be too onerous and might not be necessary. For example, Scottish Natural Heritage: "Comprehensive annual monitoring of local provision would seem unduly labour intensive, but it may be helpful to monitor the more significant changes in the extent of open space to give a broad overview of ongoing trends." The Forestry Commission also made the point that whilst regular monitoring is essential: " Stipulating an annual cycle may result in resource requirements for monitoring being too onerous."

Greenspace Scotland and sportscotland suggested that systems should be put in place for continuous monitoring of changes, with annual progress reports summarising any losses, gains and improvements over the year.