13.5 Quantity Provision Standard

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Comment

Open Spaces Strategy

Representation ID: 1197

Received: 21/10/2015

Respondent: Thurnby And Bushby Society

Representation Summary:

A possible typo: in the previous consultation, provision for children was 0.3ha/1000 people. Here it is 0.03ha/1000 people in the on-line document and 0.3ha/1000 in the pdf. Is the on-line figure a typo?

Full text:

Re Chapters 3 and 6

There is an implication in the way that the Document is worded that HDC will work towards public access for all Open Spaces. There cannot be public access to all Open Spaces.

Even where access is necessary for informal or formal recreation, restrictions may be necessary for security, environment and safety reasons e.g. on school playing fields, golf courses and nature reserves.

For areas in public ownership, e.g. amenity areas and village greens, some may be too small for anything other than the siting of a seat.

For areas in private ownership, e.g. woodlands and disused railway lines, if public access is being negotiated the problems for the landowners will have to be addressed, even for a leasing arrangement. They are:
- Insurance for personal liability
- Maintenance
- Vandalism/noise/litter
- Security
Landowners will not want the extra responsibility and an increased burden of financial liabilities.

All designated Open Space of whatever type and whether publically or privately owned should be protected by HDC Policies.

Re Chapter 8

Access is not essential for enjoying and benefiting from Open Space e.g. a view is uplifting even if you don't, or can't go into that space.

We suggest there should be an additional Open Space category that should be designated in order to preserve it:
"Visual Amenity Open Space"

This would include publically owned land that is too small for even limited informal recreation. Also it would include privately owned land where there is limited or no public access at all.

See the following table:-

Site description Ownership Limitations

Village Greens

Small open spaces within built-up areas Public
(a) Small size
(b) Possible danger from surrounding roads
(c) Restrictions on ball games
School playing fields. Private Security
Sports grounds e.g. Golf courses, Bowling greens ditto Playing surface areas cannot be walked on by public. Possible danger from balls
Domestic cutilages strategic to street scene ditto
Re sections 3.6.3 and 8.4
Disused railway lines and
other sensitive ecological areas ditto Owners would not want public access to what is often part of their curtilage
Disturbance by people not always in the best interest of the wildlife


Re Chapter 9 or 11

Open Spaces on New Developments

Getting developers to comply with conditions on Open Spaces is important and the Council needs to have the means to do this.

Maintenance of the open spaces is often contracted to a private Company and the costs charged as a levy on the residents. Many residents resent this for many reasons including:
* anyone from outside the development can use the Open Spaces which the residents are paying for
* the Company's performance can leave a lot to be desired - infrequent visits and jobs neglected.
The Council needs to be aware of this and devise a better arrangement. If the maintenance is contracted out then the Company must be chosen carefully and closely monitored.

Re section 13.5.6

A possible typo: in the previous consultation, provision for children was 0.3ha/1000 people. Here it is 0.03ha/1000 people in the on-line document and 0.3ha/1000 in the pdf. Is the on-line figure a typo?

Re section 13.6.4

Another possible typo: for natural and semi-natural areas the on-line consultation has a time/distance of 20 mins walk/13.6 km. These are not compatible or equivalent! The pdf has 20 mins walk/1.6km which looks ok.

Comment

Open Spaces Strategy

Representation ID: 1201

Received: 21/10/2015

Respondent: William Davis Limited

Representation Summary:

Quantity Provision Standards
We would support the overall approach to addressing sufficiency of open space provision (paragraph 13.5.4-5), however it is not clear at what stage this advice is offered. Under paragraph 15.12 (5th bullet point) a commitment is set out to ensure that open space provision is considered early in the development process and in development briefs. Yet at 27.4.4 the proposed amended guidance for developers `Provision for Open Space Sport and Recreation', notes that "HDC will use the most up to date information concerning current open space provision to undertake a bespoke analysis on behalf of the development industry as planning applications are made." This is not early enough in the development process. We need this information during the pre-application process in order to properly inform both Masterplan design and heads of agreement for the Section 106 agreement. The Strategy should set out a commitment to provide this information at the formal pre-application stage and where no information is offered it should be assumed that no provision for open space, sport or recreation is required.

Full text:

OPEN SPACE STRATEGY: PROVISION FOR OPEN SPACE SPORT AND RECREATION 2015
Thank you for the opportunity to comment on the Council's Draft Open Spaces Strategy. Please see our comments below:
Management of Open Space
Paragraphs 11.3.1 and 11.3.5 state that the adoption of land should be offered to the Parish Council and District Council in the first instance, however no justification for this approach has been provided. If a developer wishes to pursue a management company approach they should be free to do so. This may be important for the viability of a development.
Quantity Provision Standards
We would support the overall approach to addressing sufficiency of open space provision (paragraph 13.5.4-5), however it is not clear at what stage this advice is offered. Under paragraph 15.12 (5th bullet point) a commitment is set out to ensure that open space provision is considered early in the development process and in development briefs. Yet at 27.4.4 the proposed amended guidance for developers `Provision for Open Space Sport and Recreation', notes that "HDC will use the most up to date information concerning current open space provision to undertake a bespoke analysis on behalf of the development industry as planning applications are made." This is not early enough in the development process. We need this information during the pre-application process in order to properly inform both Masterplan design and heads of agreement for the Section 106 agreement. The Strategy should set out a commitment to provide this information at the formal pre-application stage and where no information is offered it should be assumed that no provision for open space, sport or recreation is required.

How the polciy operates

The density figure of 35 dwellings per ha is too high. A more realistic figure of 20 dwellings per ha should be used

Comment

Open Spaces Strategy

Representation ID: 1216

Received: 21/10/2015

Respondent: Sport England

Representation Summary:

It is Sport England's view that the Open Space Strategy - does not constitute a robust quantitative and qualitative assessment of the need for sport and recreation facilities, Notwithstanding the above Sport England understands that plans may be developing to undertake a Playing Pitch Strategy we would strongly support the development of such a strategy to address this issue.

Full text:

Sport England does not object to the Council reviewing its policies in relation to Open, Space, Sport and Recreation. Sport England supports the Council's intention to meet the requirements of paragraph 73 of the National Planning Policy Framework.

However, Paragraph 73 of the NPPF requires a different approach to determining need for sport and recreation compared to that included in the former PPG17 and its associated documents. The NPPF paragraph 73 requires Local Authorities to assess needs and quantitative or qualitative deficits or surpluses of sports and recreational facilities in the local area. Information gained from the assessment should be used to determine what open space, sports and recreation provision is required. For assessing the need for sport and recreation, the Government has advocated the use of Sport England's Playing Pitch Strategy Guidance and Assessing Needs and Opportunities Guidance, it does not advocate the use of the deleted Assessing Needs and Opportunities Companion Guide attached to PPG17 which uses the 'standards' approach.

Para 70 requires authorities to plan positively, without an appropriate assessment of what the existing and understanding the future needs it difficult to ensure that the right facilities are in the right place.

See the Governments website
http://planningguidance.planningportal.gov.uk/blog/guidance/open-space-sports-and-recreation-facilities-public-rights-of-way-and-local-green-space/open-space-sports-and-recreation-facilities/

The study promotes the use of the Fields in Trust standard this is not considered to be appropriate having regard to NPPF. WE raised issues around the lack of a robust evidence in the local plan consultation 2013 and our comes on the first draft April 2015

It is Sport England's view that the Open Space Strategy - does not constitute a robust quantitative and qualitative assessment of the need for sport and recreation facilities, Notwithstanding the above Sport England understands that plans may be developing to undertake a Playing Pitch Strategy we would strongly support the development of such a strategy to address this issue.