Open space strategies regulations and play sufficiency assessments regulations - drafts: consultation analysis

1. Introduction

1.1 Introduction

The joint consultation on the draft Open Space Strategies (OSS) regulations and Play Sufficiency Assessments (PSA) regulations forms part of the Scottish Government's wider programme of work implementing the Planning (Scotland) Act 2019. The Act introduced new duties on planning authorities to prepare and publish Open Space Strategies and to assess the sufficiency of play opportunities in their area for children. The Act requires the Play Sufficiency Assessment to be prepared to form part of the Evidence Report that informs the preparation of the new style Local Development Plans (LDPs), also being introduced at the same time.

More broadly, access to quality open spaces, play opportunities and green infrastructure is closely linked to strategic priorities such as the delivery of 20-minute neighbourhoods and the creation of pleasant, liveable, healthy and resilient places for communities across Scotland. The new OSS and PSA duties are also relevant to the wider policy context with regards to eliminating discrimination, advancing equalities, supporting Scottish Government's ambition in making Scotland 'the best place to grow up in' and upholding Children's Rights, as set out in the UN Convention on the Rights of the Child.

Having identified important crossovers and overlaps between the issues involved in planning for open spaces and for play spaces, the Scottish Government adopted a dual and holistic approach to developing the respective draft regulations for OSS and PSA. It has been widely noted, for example, that children do not only play in formal play parks, but rather do so across a wide range of different kinds of open spaces in their local communities and elsewhere.

As part of this dual and holistic approach, the Scottish Government worked in collaboration with a range of stakeholders in developing the draft regulations. This included a Core Group consisting of representatives from Greenspace Scotland, Play Scotland, NatureScot and Public Health Scotland, and a wider Working Group incorporating a wider selection of stakeholders with interests in open spaces and play. Local authorities and Heads of Planning Scotland (HOPS) were represented in the Working Group by two nominated local authority officers.

Additionally, during an early stage of developing the draft regulations, and working through the Improvement Service and HOPS, every local authority in Scotland was contacted about the work. Presentations and interactive workshop sessions were held with local authority representatives. Throughout the development stage, 66 local authority contacts have been involved in various discussions.

1.2 The Consultation

The public consultation ran from 17th December 2021 to 31st March 2022. It sought to gather the views of stakeholders and the public with regards to the draft regulations concerning Open Space Strategies and Play Sufficiency Assessments. The consultation covered three main areas:

• Draft Open Space Strategies Regulations;
• Draft Play Sufficiency Assessments Regulations, and;
• Partial / Interim Impact Assessments.

The consultation had 22 questions which included both closed and open sub-questions. Respondents were able to provide a response via Citizen Space (the Scottish Government's online portal for public consultations), by email or in writing.

In addition to the main public consultation, a Children and Young People's (CYP) survey was designed and coordinated by Play Scotland. This included 8 questions for primary school aged respondents, and 14 questions for secondary school aged respondents. This element of the consultation sought to gather the views of children and young people on issues relevant to the subject of the consultation. The CYP survey focused mainly on gathering perceptions with regards to the quality and quantity of the open spaces and play areas that children and young people have access to in their local areas.

Play Scotland promoted the opportunity widely amongst its networks. As part of this, all primary and secondary schools across Scotland were contacted and encouraged to participate in the online surveys or to run their own group discussions and submit their responses to Play Scotland. Play Scotland provided a 'Facilitator's pack' which gave guidance and advice on engaging individual children or groups in the survey. The pack encouraged those working with children to do preparatory work, which aimed to stimulate children's thinking and ideas and ensure responses were as meaningful as possible.

Specific survey questions were provided as a structure for engagement. However, Play Scotland encouraged the use of a wide range of different and creative engagement methods. As a result, contributions were made in a range of formats. These were collated into a single spreadsheet and submitted to the Scottish Government. In some cases, initial analysis was carried out by Play Scotland to interpret or summarise the data gathered.

1.3 Methodology

The approach to the analysis of the consultation proceeded in three stages.

Stage 1 aimed to check and validate the data which would be the subject of the analysis. Initially, this involved collating all the data from both the main consultation and the CYP survey in a master spreadsheet. Next, the project team at Horizons Research set out to review and 'clean' the data by identifying any potential defamatory responses, any potential campaign responses, blank forms and duplicate responses. After receiving confirmation from the Scottish Government and Play Scotland where necessary, we then removed responses identified as blank or duplicate from the master database, carefully recording all changes made to allow accurate auditing. No responses were identified as being potentially defamatory or part of a campaign.

This initial stage also involved identifying those respondents who had asked to remain anonymous. This allowed the researchers to identify responses to quote from - those in which the organisation or individual had agreed for both their response and name to be published. We worked with the Scottish Government to agree appropriate respondent categories for respondents to the main consultation, ensuring these were relevant and appropriate for further analysis. The agreed respondent categories are shown in the table in section 1.4, and used in tables throughout this report.

During Stage 2, we undertook a quantitative analysis of the demographic profile of respondents and of responses to the closed questions in the main consultation and CYP survey. This involved the development of formulae for the quantitative calculations and the production of tables to present the results. All numeric and percentage analysis of the closed questions has also been broken down by respondent category.

Finally, Stage 3 was the qualitative analysis of responses to all open questions in the main consultation and the CYP survey. This stage involved an initial read of all comments made in response to these questions, followed by the identification of key emerging themes, trends and the most appropriate processes for coding and analysis.

In the qualitative analysis of the main consultation, the following terms have been used to consistently indicate the frequency with which a theme or point was raised:

• Few - meaning up to 3 responses;
• Several - meaning 4 to 9 responses; and
• Many - meaning 10 and over responses.

It is worth noting that similar points were regularly made both by those expressing agreement and those expressing disagreement. Often, comments focused on broader themes beyond the detail of the regulations being asked about. We have included this wider discussion in our analysis, as these points may be relevant to the development of future guidance or policy.

Throughout this report tables are used to summarise the quantitative analysis of the data collected from the closed questions on the main consultation, and data collected from individual and group responses to the CYP survey.

Chapter 2 provides an analysis of the main public consultation. It includes summary tables of the quantitative data collected from the main consultation. The closed questions in the main consultation asked respondents to identify if they agreed, disagreed or had no view. The tables show the number of respondents in each respondent category who selected each option, and the number who didn't respond. At the bottom of each table there is a percentage figure to indicate the proportion of respondents answering the question that selected each option. It is worth noting that there was broad support for all the points asked about in the main consultation. The qualitative analysis often picks up points of support or disagreement where at least a few stakeholders discussed this, and explores the wider points being made. Quotes have been used to illustrate key themes.

Chapter 3 then provides an analysis of the consultation with children and young people, conducted via the CYP survey. This largely takes the form of a qualitative analysis of responses to the open questions in the survey. It also includes summary tables showing the quantitative analysis of data collected from the closed questions in the survey, where this could be analysed in a meaningful way. As a result of data being collated in different formats and initial analysis, we have not used quotes from group responses in this chapter of the report.

1.4 Respondent profile

The following two tables provide an overview of respondent characteristics to the consultations, based on data available. Firstly, a total of 68 responses were submitted to the main consultation. The table below gives a breakdown of the categories of respondents.

In addition, a total of 1066 primary and secondary aged respondents were involved in the consultation process through the CYP survey. There were 140 of these who submitted individual responses to the survey^[1]. A further 926 individuals were involved in 36 group responses. The following tables provide an analysis of the profile of all those involved in the CYP survey.