Open Space Strategies and Play Sufficiency Assessments Regulations: impact assessments
Impact assessment for the consultation paper on Open Space Strategies and Play Sufficiency Assessments, which discusses proposed provisions and seeks views on both sets of draft regulations.
Appendix A: Interim Equality Impact Assessment
Consultation on Draft Regulations on Open Space Strategies and Play Sufficiency Assessments
Description of Policy
Title of policy/ strategy/ legislation: Consultation on Draft Regulations on Open Space Strategies and Play Sufficiency Assessments.
Minister: Mr Tom Arthur, Minister for Public Finance, Planning and Community Wealth
Lead Official: Ian Gilzean, Chief Architect
Planning & Architecture Division
SG Officials involved in EQIA
Name: Kristen Anderson
Team: Planning & Architecture Division
Name: Kuan Loh
Team: Planning & Architecture Division
Directorate: Local Government and Communities Directorate
New policy and/or legislation: New secondary legislation, to provide more detailed provisions for planning authorities to support their new statutory duties on preparing Open Space Strategies and Play Sufficiency Assessments.
Screening
Policy Aim
New statutory duties[3] on planning authorities[4] to prepare and publish an open space strategy, and to assess the sufficiency of play opportunities in their area for children, were introduced in The Planning (Scotland) Act 2019[5].
The aim of the provisions is to provide direction to planning authorities to help them meet their legal duties. The provisions seek to ensure, in preparing Open Space Strategies (OSSs) and Play Sufficiency Assessments (PSAs), planning authorities cover certain minimum aspects, including around accessibility, quality and quantity of open spaces and play opportunities. They also aim to ensure appropriate and meaningful engagement is carried out to inform the assessment of play sufficiency and the assessments of current and future requirements in relation to open space, green infrastructure and green networks. The provisions seek to provide a robust framework of legislation, including in relation to consultation (setting out groups to be consulted) and publication, without imposing unnecessary financial and administrative burdens on planning authorities.
Both sets of provisions contribute to the following national outcomes contained in the National Performance Framework:
- We grow up loved, safe and respected so that we realise our full potential
- We value, enjoy, protect and enhance our environment
- We live in communities that are inclusive, empowered, resilient, and safe
- We are healthy and active
The development of open space strategies can also help contribute to improving performance against the national indicator on access to green and blue space[6].
The new legislation on the preparation of OSSs and PSAs forms part of Scottish Government's wider ambitions for evidence-led planning and placemaking, to help shape greener, healthier, more inclusive and child-friendly environments.
The public consultation will seek views on the proposed draft Regulations with regards to the procedures and form and content relating to open space strategies and play sufficiency assessments, and their potential impact on people and children of different protected characteristics.
Who will it affect?
We envisage the provisions in the draft Open Space Strategies Regulations have the potential to affect those who use and have an interest in open spaces, green networks and other play opportunities; while the provisions in the draft Play Sufficiency Assessment Regulations have the potential to affect anyone aged 0 -17 who plays outdoors, as well as parents and carers. As the PSA is to be carried out in preparing an Evidence Report, for local development plans (LDPs) they should therefore influence an area's spatial strategy, and local planning provision of play opportunities for children.
Equality legislation covers the protected characteristics of: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion and belief, sex (gender) and sexual orientation. The draft Regulations have the potential to affect everyone so the scope of this interim equality impact assessment (EQIA) is extended beyond the list of protected characteristics to include wider socio-economic considerations.
Across the two sets of draft Regulations there are specific requirements for planning authorities to consult children and young people, disabled people, parents and carers, older people, the public, community councils and any other person or community body which the planning authority considers to be appropriate.
A major benefit of the secondary legislation will be its potential to positively impact on access to open space and play opportunities, linked to other outcomes around improving health and wellbeing, creating successful sustainable places and improving equality and eliminating discrimination.
The link between green space and well-being is well established. Studies have shown that people experience less mental distress, less anxiety and depression, better well-being, and healthier cortisol levels (the hormone that controls mood) when living in urban areas with more green space compared to less. Green space use is associated with increased levels of social interaction and physical activity, and decreased levels of all-cause mortality, loneliness and stress. Additionally, there is evidence that contact with green space may disproportionately benefit disadvantaged populations, reducing health inequalities and weakening the effects of poverty[7].
The impact on spending time in greenspace is particularly important for children as it provides opportunities and space to play and experience the natural world. The positive impacts of quality greenspace for children includes the ability to cope with life stresses, concentration, activity levels and social skills,[8,9]. The Child Rights and Wellbeing Impact Assessment (CRWIA) provides further detail on the potential impact of the draft Regulations on children and children's right (Appendix B).
What might prevent the desired outcomes being achieved?
We have not identified any insurmountable factors which might prevent the desired outcomes.
Planning authorities have raised some concerns about the resource implications for them of meeting their new statutory duties of preparing their OSS and PSA. Therefore, we have sought to develop the two sets of draft Regulations together, to help, as far as possible to ensure alignment and resource efficiency, giving potential for aligning activity to meet the requirements across the two duties (as covered in the BRIA).
Open space and play opportunities, can contribute to multiple benefits and outcomes; ensuring these are all achieved may require a joined-up, corporate approach across a council. Discussions with local authorities found they were generally content with the suggested outcomes approach, recognising it ties in with the holistic place-based approach and delivering cross-cutting benefits. There were also some comments about an outcomes based approach having potential benefits in securing corporate buy-in and resource from across the Council. We intend to cover this and other aspects of good practice in any future supporting guidance.
Stage 1: Framing
Results of framing exercise
The Scottish Government's Planning & Architecture Division is leading on the preparation of the draft Regulations, which adopted a collaborative approach in developing the proposals.
The new duties on Open Space Strategies and Play Sufficiency Assessments have the potential to impact on everyone living in Scotland. So to inform the drafting, we have carried out engagement with a broad range of stakeholders around the detailed provisions for the secondary legislation prior to this formal consultation.
Human Rights
As noted in the Equality and Fairer Scotland Budget Statement (2021-22)[10] the norms and standards contained in international human rights conventions include not only the civil and political rights found in the European Convention of Human Rights – but also economic, social and cultural rights. Key rights, relevant to the draft Regulations include the right to the highest attainable standard of physical and mental health; to education; the right to take part in cultural life; and, freedom of assembly. UN treaties also provide specific rights and protections against discrimination in the enjoyment of a wide-range of human rights for women, children, disabled people, and ethnic, religious and other minorities.
Obligations set out in international human rights treaties are legally binding as a matter of public international law and (unless specific exceptions are made) they apply to the UK as a whole. Public authorities in Scotland, as in other parts of the UK, should therefore act in a way that gives proper effect to these rights, in accordance with the undertakings entered into by the UK when it ratified the relevant treaties.
Whilst there is not currently a specific Human Rights Impact Assessment, Human Rights issues are considered as part of this EQIA.
Scotland's National Performance Framework includes the human rights outcome – 'We respect, protect and fulfil human rights and live free from discrimination'. The outcome includes three indicators, one of which is measured as the percentage of respondents who agree with the statement "I can influence decisions affecting my local area", as measured by the Scottish Household Survey. In 2019[1], only one in five adults (18%) agreed that they can influence decisions affecting their local area, while 30% said they would like to be more involved in the decisions their council makes, a decrease from 38% in 2007. Generally, older adults were more likely than younger adults to say they are satisfied with local government performance and less likely to want to be more involved in making decisions.
Both sets of draft Regulations include requirements to consult; such engagement opportunities should support the national indicator for people to influence decisions which affect them.
Children's Rights
A number of The United Nations Convention on the Rights of the Child (UNCRC) articles are directly relevant to the draft Regulations, in particular, Article 31 (leisure, play and culture) which relates to every child having the right to relax and play; Article 15 (freedom of association) under which, every child has the right to meet with other children and to join groups and organisations, as long as this does not stop other people from enjoying their rights; and Article 12 (respect for the view of the child) every child has a right to express their views and to have them considered and taken seriously.
Further, in ensuring equality of opportunities and acting in the best interest of the child, Article 3 (best interest of the child); Article 23 (children with a disability), under which a child with disability is supported to live a full and decent life; and Article 24 (health and health services) where a child has the right to the best possible health are also relevant to the draft Regulations.
The United Nations Convention on the Rights of the Child (Incorporation) (Scotland) Bill (the Bill) was unanimously passed by the Parliament in March 2021. This landmark legislation was meant to deliver a fundamental shift in the way children's rights are respected, protected and fulfilled.
However, the Supreme Court's judgement on the Bill on 6 October 2021 found each of the provisions referred by the UK Law Officers to be outwith the legislative competence of the Scottish Parliament and to this end, the Bill could not receive Royal Assent in its current form. The Scottish Government is clearly disappointed by, but respects, the Court's judgment.
Despite this, the Scottish Government remains committed to the incorporation of the United Nations Convention of the Rights of the Child to the maximum extent possible and are considering the implications of the judgement and how best to take things forward. At the time of preparing this report, the majority of work in relation to implementation of the UNCRC is continuing.
Engagement
In developing the proposals, Scottish Government officials have been working with a Joint OSSPSA Working Group with representatives from a range of external stakeholders. The OSSPSA Working Group has acted as a sounding board in preparing the proposals for both sets of draft Regulations. The OSSPSA Working Group includes representative interests from both the open space and play sectors from; Greenspace Scotland, Play Scotland, Green Action Trust, A Place In Childhood, Learning Through Landscape, Inspiring Scotland; plus agencies; Architecture & Design Scotland, Nature Scot, Public Health Scotland, SEPA, SportScotland, Scottish Forestry; and from local authorities officers representing their councils and Heads of Planning Scotland, and the Improvement Service.
We have also engaged across Government: with statisticians; officials at National Records of Scotland and officials from Children and Families; Early Learning and Childcare and Natural Resources teams.
Under the guidance of the Working Group's Core Group, the team has undertaken a range of research and engagement activities. This has included holding workshops and group discussions with various stakeholders, and inviting views on focused issues.
As much of the engagement took place during the period under the restrictions due to the pandemic, apart from the engagements pre-pandemic, most of these were held digitally and via online platforms.
A summary of activities is as follows:
- Working Group Meetings: including national organisations and groups representing a variety of equality issues and interests to discuss and contribute to the design of the draft Regulations. These included workshops and presentations. Presentations highlighted existing inequalities in access to green space, particularly among ethnic minorities and those from more deprived backgrounds.
- Focussed Workshops: these were similar to the wider Working Group sessions but focussed in on specific issues. This included a screening of the 'Mountains for All' EQIA video[11], to highlight the need to consider equality issues when helping develop and commenting on the proposals.
- Presentation to Heads of Planning Scotland: the Heads of Planning Scotland network represent senior officers in planning authorities, whose teams will be required to implement the new duties.
- Written paper and feedback: proposals were shared with officers from local authorities along with a workshop session including a presentation and discussions to inform the preparation of the proposals. Subsequent written feedback was received from planning authorities;
- Data gathering: a range of evidence and sources were used to populate this framing exercise regarding people potentially affected by open space strategies and play sufficiency assessments (see references at the end of this document (Appendix G);
- Evidence from existing large national and UK surveys: including the Scottish Household Survey, these were primarily in relation to health and access to open space.
Initial Summary Reflection
As this is an interim equality impact assessment, it is not intended to be a definitive statement or a full assessment of impacts. It does however present preliminary and indicative impacts that will require further consideration by the Scottish Government to inform the decision-making process on the secondary legislation on open space strategies and play sufficiency assessments after the public consultation has taken place, prior to finalising the Regulations to lay in Parliament.
In this interim EQIA we look at published evidence available and gathered so far under the protected characteristics as listed within the Equality Act 2010: Age, Disability, Sex, Pregnancy and Maternity, Gender Reassignment, Sexual Orientation, Race and Religion or Belief. In addition, as the draft Regulations have the potential to affect everyone, and there is evidence around inequality due to poverty and socio-economic circumstances, the scope of this interim EQIA is extended beyond the list of protected characteristics to include wider socio-economic considerations and considers people living in poverty and/or in low income households, and relevant human rights. Data and qualitative information has also been gathered from evidence arising from stakeholder workshops, discussions and other research and publications.
It is important to note that the protected characteristics listed along with the other socio-economic considerations are not independent of each other, and some people may have to deal with complex, multiple and interconnected issues related to disadvantages at any one time.
Initial reflections from the evidence gathering and engagement to date indicate that the design of the provisions may potentially have an impact on some people and/or communities, directly or indirectly, and in different ways. This includes people with protected characteristics and other socio-economic challenges and the reflection has identified a broad range of potential impacts.
The initial indications of the main issues primarily are:
Protected Characteristic: Age
The evidence shows that children frequently want 'lots of green spaces' and 'more places to play'. The evidence shows that children play differently in play spaces and open spaces depending on their age, and stage of development. So they may have different needs and/or preferences of the type of play space / open space for play, relaxation or hanging around depending on their age.
Older children and teenagers are often the forgotten users in parks and play spaces. In some new developments, their needs may be neglected, perhaps due to a focus on those families with young children who tend to be the target market. Teens also experience a greater degree of hostility to their presence in public space both from others in the community and from the neighbouring public and commercial agencies.[12]
The primary concern for older people is with regard to accessibility of open spaces. The accessibility of spaces may affect older people especially those with disabilities, less mobility, dementia, and/or other long-term health conditions.
The evidence suggests that the majority of young people feel they should be involved in planning in their local area. Being able to meaningfully participate in the processes around planning and assessments is highlighted to be crucial, to ensure everyone is given the fair opportunity to be involved and heard.
The indications are that using internet and social media to communicate and engage with young people, will be essential but that this is perhaps not the most effective communication medium for older age groups. Other non-internet based communication methodologies should also be considered to take into account the levels of digital literacy across different age groups.
Protected Characteristic: Disability
Evidence from national surveys and research suggests that a high percentage of households in Scotland have someone with a disability or who has a long-term health condition. Data shows that fewer people with a limiting long-term health condition responded that they live within 5 minutes' walk of their nearest green or blue space, compared to those without such a health condition. Evidence also reveals barriers to disabled people's use and enjoyment of parks and greenspaces and how these can be addressed.
The 'accessibility' of open spaces and play opportunities is vital in terms of advancing equality of opportunity for children and other people with disabilities and health issues affecting mobility and/or other physical impairment. We propose to ensure both sets of draft Regulations require that this aspect is considered in carrying out PSAs and preparing OSSs. Future shared good practice and guidance will reflect more details on a broad range of disabilities and health issues exist and that some people may have complex and interconnected needs. Consideration should be given to ensuring accessibility, and maximising inclusion where appropriate.
Protected Characteristic: Sex/Gender
The evidence suggests women are likely to have greater concerns about their personal safety travelling to/from and within parks and green spaces. Evidence shows that women are under-represented in their use of green space, proportionate to their numbers in society, and that women's use of urban green space may be influenced by the quality of the green space to a greater degree than men's.
Make Space for Girls[13] also highlighted how girls are crowded out of parks and equipment, and how their needs are mostly ignored and that parks, play equipment and public spaces for older children and teenagers are currently designed for the default male. Provision is almost entirely in terms of skate parks, BMX tracks, football pitches and multi-use games areas (MUGAs), which are used almost entirely by boys.
There are clear differences in the ways that boys and girls use and experience urban neighbourhoods and spaces. Boys enjoy greater freedom of mobility and are more populous and visible in playgrounds, parks and public spaces than girls and tend to dominate informal public sports areas such as ball courts, skate parks and the like. It is landscape-led design principles that hold the key to creating more gender equal spaces. Gender-sensitive engagement initiatives, and measures to improve female representation in planning and design professions are also vital in improving access and design for girls and young women.[14]
As safety and the quality of spaces is particularly important to girls and women, the draft OSS Regulations require open space audits to include statements on the 'accessibility' and 'quality' of the open spaces and green networks in respect of each locality within their area, and for the totality of their area. Future shared good practice and guidance will provide more detail on the types of considerations that contribute to quality, and is likely to link to the six qualities of successful places set out in Draft National Planning Framework 4, including being 'safe and pleasant', which is currently covered in Scottish Planning Policy.
Protected Characteristic: Race
There is a marked difference by ethnicity in terms of living within a 5-minute walk of the nearest greenspace, with just 45% of ethnic minorities reporting living within a 5-minute walk, compared to 66% of those from the white ethnic group. The draft OSS Regulations include outcomes around 'advancing equality and eliminating discrimination' and 'improving access to green infrastructure, open space and green networks'. These are intended to work together to ensure good access for people from all backgrounds.
Natural England's 'People and Nature Survey (children)'[15], published in October 2020, has revealed clear inequalities for children engaging with nature, with 71% of children from ethnic minority backgrounds reporting spending less time outside since coronavirus compared with 57% of white children.
Protected Characteristic: Religion / Belief
The data reveals that Christians or those having no religion were significantly more likely to live within 5 minutes of a greenspace compared to those belonging to another religion ( 63.61% of Christians, compared to 48.09% of those from other religions). The draft OSS Regulations include outcomes around 'advancing equality and eliminating discrimination' and 'improving access to green infrastructure, open space and green networks'. These outcomes are intended to work together to ensure good access for people from all backgrounds.
Socio-economic Aspect: Low Income Households
People living in the most deprived areas are less likely than people in less deprived areas, to live within a 5 minute walk of their nearest greenspace. Access to outdoor space at home varies by tenure, with homeowners being more likely to have access to private gardens. In terms of quality, respondents living in the 15% most deprived areas of Scotland were more likely to agree or agree strongly that the quality of their local greenspace has reduced in the past 5 years.
Almost one in four of Scotland's children live in poverty, and the evidence shows this can impact on their opportunity to play, and how they play.
Evidence also indicates that internet access and confidence in using it varies by tenure and household income.
Positive Impacts
Through the preparing of the proposed draft Regulations we have sought to address issues around equalities to help ensure equity of access to open spaces, green networks and play opportunities, and to ensure people have the chance to be involved in decisions affecting them around open space and play opportunities. The intention is that the draft Regulations will help create the conditions for a number of positive impacts including in relation to:
- advancing equality and eliminating discrimination and improving access to green infrastructure, open space and green networks;
- sufficient suitable, accessible quality opportunities for children of all ages to play;
- improving access to play opportunities that are suitable for children with disabilities and other protected characteristics;
- the quality of open space and play opportunities;
- supporting wider outcomes including; improving health and well-being; climate change mitigation and adaptation; securing positive effects for biodiversity, placemaking - creating successful and sustainable places:
- providing opportunities for people of different ages and backgrounds to be consulted, to ensure they have their views heard in relation to play sufficiency and open spaces in their communities.
Iteration
The EQIA will be further developed, building on this interim EQIA, and will take into account the views of a wide range of stakeholders through the feedback gathered from the public consultation. The consultation includes specific material that highlights aspects of the draft Regulations that may impact on and/or benefit equality of opportunity.
These responses will be taken into account together with any additional evidence gathered during the consultation.
The full and final EQIA will consider how, through the regulations, future shared good practice and guidance, we can: address any unintended or consequential impacts on people; enhance actions to reduce inequality; and where necessary, take action to avoid discrimination. Where gaps in evidence highlighted in the consultation responses, we will seek to identify evidence to fill these gaps, and may engage with relevant representative organisations.
Interaction with Other Policies (Draft or Existing)
Scottish Planning Policy
Scottish Planning Policy[16] (SPP) (2014) provides Scottish Government policy on nationally important land use planning matters, and is a material consideration to be taken into account in planning decisions. SPP sets out that development plans should be informed by relevant, up-to-date audits, strategies and action plans covering green infrastructure's multiple functions, including open space, playing fields and pitches. SPP states plans should promote consistency with audits and strategies and reflect their priorities and spatial implications. SPP states that, development of land allocated as green infrastructure for an unrelated purpose should have a strong justification. This should be based on evidence from relevant audits and strategies that the proposal will not result in a deficit of that type of provision within the local area and that alternative sites have been considered.
National Planning Framework 4 (Draft)
National Planning Framework 4, will set out a long term vision for Scotland's spatial planning and development. NPF4 will incorporate SPP, so for the first time, spatial and thematic planning policies will be addressed in one place.
To provide an overview of our policy thinking, in November 2020 the Scottish Government published a Position Statement[17] setting out our thoughts on what the likely policy changes might be in the draft NPF4. The Draft NPF4[18] was laid in Parliament on 10 November 2021, and it sets out the policy framework on blue and green infrastructure, play and sport, which will underpin the implementation of these two new duties.
Draft NPF4 recognises networks of blue and green infrastructure are an integral part of successful places and that blue and green infrastructure can offer a wide range of benefits. It notes accessible, high quality natural and civic spaces can be used by communities for many activities: exercise and recreation, play, sport and connecting with nature.
Draft NPF4 also highlights outdoor spaces for play, sport and recreation can make a significant contribution towards creating more liveable and healthier places. It notes children experience a range of health, wellbeing and educational benefits from outdoor play, and learning in, and connecting with nature. Providing quality opportunities for children of all ages to play will benefit their physical and cognitive development, and uphold their right to engage in play and recreational activities.
Draft NPF4 says the planning system should support development that expands opportunities for play in the public realm and in a range of different types of open and green spaces, and which addresses unequal access to play spaces and facilities.
Specifically, it provides a policy framework (at policy 12a) which sets out that local development plans should identify and protect blue and green infrastructure - open space audits may inform the areas protected.
Also in terms of protection (at policy 12c) it states 'Development proposals that result in fragmentation or net loss of existing blue and green infrastructure should not be supported unless it can be demonstrated that the overall integrity of the network of blue and green infrastructure will be maintained.' Additionally (at 12f) it sets out development proposals that result in the quantitative and/or qualitative loss of children's outdoor play provision should not be supported, unless it can be demonstrated that there is no ongoing or future demand or such provision is replaced by a newly created, better quality or more appropriate provision.
Draft policy 12a also requires plans to identify opportunities to enhance and expand provision and access to blue and green infrastructure (at strategic and local scales) - planning authorities may use the policies and proposals in their Open Space Strategy to inform this.
It also says (at policy 12b) local development plans should identify new, enhanced provision or improved access to play opportunities for children as part of enhancing and expanding blue and green infrastructure. Blue and green infrastructure should provide opportunities for play and recognise the need for, and provide publicly accessible, outdoor opportunities for formal, informal and incidental play. These facilities should be good quality, accessible and suitable for different ages and abilities, to satisfy current and likely future needs and demand in the community.
Draft NPF4 sets out (at policy 12h) that development proposals should incorporate and enhance blue and green infrastructure wherever possible. They should be designed to be multifunctional and consistent with the six qualities of successful places. This links to the draft Regulations' requirement to consider aspects around quality. It also includes a new policy that major development proposals for new homes, and other major development likely to be used by children and young people, should incorporate well-designed, good quality provision for play, recreation and relaxation.
It also sets out (at 12j) that proposals that include new streets and public realm should incorporate the principles of Designing Streets and inclusive design to enable children and young people to play and move around safely and independently; maximising the opportunities for informal and incidental play in the neighbourhood. Although, the draft PSA Regulations do not require planning authorities to identify these informal and incidental play opportunities in neighbourhoods, but we encourage planning authorities to consider these as a way to maximise opportunities for doorstep play and 'play along the way'.
It also sets out (at policy 12k) the policy expectations of what new, replacement or improved play provision should be like, including being: inclusive; suitable for different ages of children and young people; and easily and safely accessible by children and young people independently, including those with a disability.
An extensive public consultation on Draft NPF4 is currently running and will allow further opportunities to comment on the emerging planning policies. We anticipate a final version of NPF4 being approved and adopted in summer 2022. More details about NPF4 are available online at our website: Transforming Planning.
Play Strategy
The Scottish Government commissioned Play Scotland to produce a progress report on Scotland’s Play Strategy (2013). The Progress Report[19] was published in March 2021 and included a consultation with children and young people on the effects of Covid-19 on their play experiences. The progress report contained recommendations for Scottish Government on the future of play policy, including:
- refresh the Play Strategy and ensure national and local leadership support the child’s right to play;
- renew and develop the national and local commitment to outdoor play;
- listen to children and young people and act on what they say; o ensure inclusion of all children and young people;
- ensure cross sectoral and inter-professional approaches to play are in place.
Summer of Play
In March 2021, to support recovery from the impact of Covid restrictions, funding of £20 million was provided to local authorities and partner organisations including Sportscotland, Creative Scotland, Play Scotland, Education Scotland and others. This funding was to deliver a range of activities for children and young people and their families over the summer, ensuring they were provided with opportunities to socialise, play and reconnect within their local communities and environment. In particular support was provided for those children and young people who may otherwise struggle to access such experiences during the holidays.
The funding supported existing community-based services while also widening access to other local facilities, such as school estates and local sports facilities.
Commitment to renew play parks
Programme for Government 2021[20] includes a commitment to "invest £60 million to renew play parks in Scotland, so children have access to high‑quality outdoor play in their own communities".
The Scottish Government have agreed the first allocation of funding to local authorities, in the amount of £5m for refurbishment of play parks, to commence in the first 100 days of the new parliament, with the remaining to be provided over the five years of the current parliamentary term. Ministers expect that the whole play estate will be considered, and that there will be engagement with children and young people before the local priorities are identified for this funding. It is also expected that all play parks that have been identified for refurbishment, in line with nationally agreed principles and influenced by local plans and investment priorities, will be refurbished.
Designing Streets
Designing Streets[21] is the first policy statement in Scotland for street design and marked a change in the emphasis of guidance on street design towards place-making, and away from a system focused upon the dominance of motor vehicles. It covers policy on streets as social spaces and highlights that 'A significant amount of interaction within a community takes place in the external environment, and street design should encourage this by creating inclusive social spaces where children can play, people can stop to chat, and other appropriate activities can take place safely.' It highlights the introduction of small, informal squares in a residential area can support navigation, provide social areas for people to gather and children to play, slow traffic speed and create positive character.
Place Standard Tool and Place Standard Children and Young People Versions
The Place Standard is a tool that is used to assess the quality of a place. It can assess places that are well established, undergoing change, or still being planned. The tool can also help people to identify their priorities for a particular place.
The tool is simple and free to use. It consists of 14 questions which cover both the physical and social elements of a place. The questions relate to themes and the tool provides prompts for discussions, allowing considerations to be given to all the elements of a place in a methodical way. A number of the themes are relevant to considering open spaces and play spaces when thinking about a place.
The tool is currently used by local authorities, communities and developers to help engagement and to hold conversations about a place or development.
Scottish Government and the Place Standard partners are developing versions of the tool that are suitable for children and young people, which can help future engagement with younger citizens on matters to do with their built and natural environment.
Extent/Level of EQIA required
The evidence captured in the next section entitled 'Data and evidence gathering, involvement and consultation' has been drawn from a broad range of sources.
Primarily evidence has been gathered from existing large national and UK surveys relating to use of access to green space and play spaces. Health data from Public Health Scotland has also been included, including recent research considering the impact of the pandemic on use of greenspace and inequalities, as well as the Scottish Health Survey (2020). Statistics have mainly been gathered from the Scottish Household Survey (2017, 2018 and 2019 Reports) the 2011 Census and the Office of National Statistics. Previous research studies, and other equality impact assessments and survey data have also been used to provide evidence.
A full list of references is provided at Appendix G.
Stage 2: Data and evidence gathering, involvement and consultation
This section includes the results of the evidence gathering (including the framing exercise), including qualitative and quantitative data and the source of that information, whether national statistics, surveys or consultations with relevant equality groups.
| Characteristic: Age | Source (full reference details in Appendix G) | Data gaps identified and action taken |
|---|---|---|
| Evidence gathered and Strength/quality of evidence | ||
Demographic Information Scotland's population is ageing. In mid-2019, 19% of the population were aged 65 and over compared with 17% a decade earlier in mid-2009. Over the same period, the population aged 65 and over increased in all council areas. |
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NRS' mid-2020 Population Estimates note that while Scotland's population has been increasing since 2000, growth is not consistent across all ages. The 2011 Census reports people aged 65 and over outnumbered under 15s for the first time, In the last two decades, the number of people aged 0 to 15 years (children) has decreased by 68,000 people (-7%). |
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Locational Differences Older and Younger people are not distributed evenly across Scotland. While the median age for Scotland as a whole was 42 years, the median age of data zones ranged from 19 years in 'Newington and Dalkeith Road – 03' and 'Ruchill – 04', which contain student accommodation for the University of Edinburgh and University of Glasgow respectively to 72 years in 'Falkirk - Town Centre and Callendar Park – 02' which contains a high number of elderly residents. |
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Use of / Value of Open / Green Space In Democracy Matters for Children, it notes that one of the most prominent themes was the importance of the physical environment for children. Children frequently want 'lots of green spaces' and 'more places to play', 'protected wildlife', 'more trees' , 'more bins' and provisions in place around personal safety. On leisure and socialising, children were keen for spaces for people to spend time socialising and the children valued places to be physically active both in- and outdoors. |
Democracy Matters for Children, Children's Parliament Consultation on 'Democracy Matters' August 2019[25]. |
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Eight in ten (80%) adults had taken part in physical activity and sport in the previous four weeks. The percentage of adults taking part in physical activity and sport remained stable from 2018 (80% in 2018). Participation in physical activity and sport (including recreational walking) declined with age. |
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In the survey of women and non-binary people in Glasgow of the respondents who had children, "63% indicated they would not be comfortable for children to visit this park unaccompanied by an adult. Even respondents with older children seemed disinclined to leave them unaccompanied." |
Young Women Lead 2021 Report - YWCA Scotland | The Young Women's Movement[27] |
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'For many years, even up to the 1970s and beyond, the street was a popular and significant place to play for most children. It is still a key play space for many. A 2001 survey of 800 children in Easter playschemes found that the street was the most common outdoor space for play, with 27% saying it was where they played most often. (Children's Play Council 2001). A 2003 Home Office survey showed that two-thirds of 8 - 10 year olds felt safe walking or playing in their street or block (Farmer 2005). Although hard data is not available, it is almost certain that fewer children play in the street today, and that they do so for a shorter time and in more limited ways, than in previous generations.' |
'Can I play out…?, Tim Gill (2007)[28] |
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Accessibility - Access to greenspace In 2019, those in the 75+ age group were less likely to live within a 5 minute walk of the nearest greenspace compared to younger age groups. |
National Indicator Access to Green and Blue Space Performance (data from Scottish Household Survey)[29] |
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The Scottish Household Survey 2016 reveals around nine in ten households (92%) with young children have access to some form of play areas within their neighbourhood. Around two thirds (65%) have access to a park, whilst over half have access to either a playground (56%) or field or other open space (53%). Children in rural areas have more access to fields, natural environments and woods, whereas those in urban areas have more access to parks. |
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Travel - Older people were less likely to have travelled the previous day. Only 51% of those aged 80 and over had travelled the previous day and 65% of those aged 70 to 79. |
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Children's independent mobility, or "roaming range" (the extent of the neighbourhood where children can play outside without adult supervision), has shrunk by more than 90% in 40 years and independent travel is increasingly restricted to older children. |
Parks and Play, Play Builds Children, Fields In Trust[32] |
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Streets close to home are natural meeting places, and generally places where most children feel - and are - safe from harm (assuming traffic poses no threat). The home street is also the starting point for all the journeys and trips that children make: a springboard for travelling around their 'home territory' - the area they are allowed to move around on their own. Children's mobility is much more limited today. Statistics suggest that in a single generation, for eight-year-olds it has shrunk to just one ninth of its previous size (Hillman, Adams and Whitelegg 1990; Wheway and Millward 1997). |
'Can I play out…?, Tim Gill (2007)[33] |
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Research carried out by Children In Scotland with young peer researchers from schools in Dundee and Glasgow, found that children and young people might not want to go to certain areas, including local parks and green spaces because they did not feel safe. They expressed particular concerns about drunken behaviour by adults in open spaces, and the presence of litter particularly where there's evidence of items used for taking drugs having been left. |
Health Inequalities: Peer research into the role of communities, Young peer researchers [34] |
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Use - Older people's use of greenspaces / parks An article on What Seniors Need in Parks highlights "Parks are too often created for children or able-bodied adults. But they can be designed with a set of aging principles. Through a set of 8 focus groups conducted with elderly about their park use in Los Angeles, Marshall found that they all share "an enjoyment of natural beauty, with an appreciation for tranquillity, plants, and fresh air." "Being in a park encouraged social interactions, which led to more physical activity." "Group activities — like Tai Chi in the park — lead to friendships and more exercise." "Walking is their most common physical activity, so "distance to the park affects use." "But the elderly polled were also fearful, with their greatest fear being falling. "Breaking a hip can mean losing their homes and moving into a retirement facility." For them, other primary threats were "disrespect by younger generation, robbery, drugs, and crime." Environmental threats include: "uneven ground surfaces, trash caused by the homeless, a lack of visibility with walking paths, a lack of shade, and excess heat or cold." Those with canes, walkers, and wheelchairs feel even more vulnerable outdoors." |
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Expectations that greenspaces should be good places for people to meet others from the local community were higher amongst the oldest (65+) age group (59% agreed strongly) than the 25-34 age group (47%). |
Greenspace Use and Attitude Survey, Greenspace Scotland[36] |
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Physical Activity During the fieldwork period, nearly half (46%) of all adults met the guidelines for moderate or vigorous physical activity (MVPA) of at least 75 minutes per week of vigorous activity or 150 minutes per week of moderate activity (or some combination of the two). Younger adults were more likely than older adults to meet the MVPA guidelines (50% of those aged 16-44 compared with 34% of those aged 75 and over). |
Scottish Health Survey (2020)[37] |
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Child - Overweight, obesity and physical activity Levels of child overweight and obesity increase with age. At age 6 (BC1), during 2010/11, 24% of children in Scotland were overweight or obese. By age 10, this had increased to 34%.1 BMI at age 6 is closely associated with BMI at age 10. Amongst children who were a healthy weight at age 6, 79% remained a healthy weight at age 10 whilst 20% became overweight or obese. Similarly, 79% of children who were obese at age 6 remained obese at age 10 whilst 13% became overweight and 8% were a healthy weight. At age 6 and age 10, children living in more disadvantaged circumstances were more likely to be overweight or obese than those in less disadvantaged circumstances. The difference in levels of overweight/obesity between children in these different circumstances increased with age. For example, at age 6, 24% of children living in the 20% most deprived areas of Scotland were overweight or obese compared with 22% of those living in the 20% least deprived areas. At age 10, 39% of children living in the most deprived areas were overweight or obese compared with 25% of children in the least deprived areas. |
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Benefits of greenspace to children The impact on spending time in greenspace is particularly important for children as it provides opportunities and space to play and experience the natural world. The positive impacts of quality greenspace for children includes the ability to cope with life stresses, concentration, activity levels and social skills. |
Greenspaces can help give our children the best start in life, Greenspace Scotland[39] |
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Stakeholders from the play sector have indicated in discussions that without access to quality greenspaces or play areas, and as some parents did not themselves have experience playing out when they were younger, that children may spend more time on other activities rather than playing outside. Research undertaken by the Royal College of Paediatrics and Child Health (RCPCH) found that children and young people said that in a typical day they spend an average of; 2.5 hours on a computer/laptop/tablet, 3 hours on their phone, 2 hours watching tv 41% of children said screen time have a negative impact on their play / fun time. |
The Health Impacts of Screen Time: A Guide for Clinicians and parents Royal College of Paediatrics and Child Health[40]. What do children and young people think about screen time [41] |
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Covid-19 effects on play and use of greenspace Public Health Scotland's Report 'How did COVID-19 affect children in Scotland? Report 2 Play and learning, outdoors and social interactions' provides evidence based on a survey they carried out looking at the impact of Covid and lockdown on early years resilience impacts. For over a quarter (26%) of children, parents and carers rated amount of time spent outdoors as the same as that before lockdown and for 29% they rated it as worse. However, for 45% of the children, amount of time spent outdoors was rated as better than that before lockdown. This did not differ greatly by child's age. 81% of children had played outside on at least four out of the last seven days. This was slightly higher in the younger age group (2 to 4 years) (84%), compared to the older age group (5 to 7 years) (78%,). 63% of children had been for a walk, cycle or scoot in the local area on at least four out of the last seven days; this was similar for both age groups. 32% of children had been to a park or other local greenspace on at least four out of the last seven days, while 27% had not been to a greenspace at all in the last week. As well as use of outdoor spaces, the survey asked about children's access to different types of outdoor spaces, including at home (for example, a garden or communal space), in the local area. For 91% of children, parents and carers reported that they had access to private outside space at home, whereas 2% had no access to outside space at home. Further, 13% had access to communal outdoor spaces, 8% had a private patio area and 2% had access to a balcony (percentages add up to more than 100 as respondents could select all that apply). In addition, 94% of children had access to good-quality greenspace in the local area, while 6% did not. The high proportion of children reported as having access to private outside space at home, and good-quality greenspace in the local area, is potentially influenced by the bias in the sample, with a greater proportion of participants coming from high-income households than is nationally representative. For 41% of the children, parents and carers rated their imaginative play as the same since lockdown as it had been before, for 12% it was rated as worse. However, for 46% of the children, parents and carers rated their imaginative play since lockdown as better than before lockdown. The percentage of children with improved imaginative play was higher in the younger age group, with just over half (54%) of the children in this age group rated as having improved imaginative play compared to 38% of older children. |
'How did COVID-19 affect children in Scotland? Report 2 Play and learning, outdoors and social interactions' Public Health Scotland's Report [42] |
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A COVID-19 Survey (2020) reported that young people (aged 10 to 16 years) participating in a small number of workshops in Scotland identified lack of access to the outdoors as one of the main challenges they experienced during lockdown. These young people felt that the restriction on parks and limited opportunities to access the outdoors had affected their health and wellbeing. |
COVID-19 Survey (2020)[43] |
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Slower cognitive decline Research suggests contact with greenspace may play a positive role against cognitive decline in the elderly. In particular, the research shows that the loss in cognitive functions expected as part of the aging process is slightly slower in people who live in greener neighbourhoods. |
Residential Surrounding Greenness and Cognitive Decline: A 10-Year Follow-up of the Whitehall II Cohort. Environmental Health Perspectives, 2018 IS Global[44] |
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Sense of belonging to their community The Scottish Household Survey reveals almost nine in 10 adults (87%) aged 75 and above said they felt a very strong or fairly strong sense of belonging to their community, compared to just over seven in ten (73%) of those aged between 16 and 24. Provisions that help improve the quality of places and neighbourhoods, including quality open spaces and play opportunities, could reasonably be predicted to have a positive impact on people's sense of neighbourhood generally, and particularly for young people. |
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Engagement in Planning / Place The majority of young people feel they should be involved in planning in their local area and that their local councils should look at ways to support children and young people to do this. |
YoungScot survey (2017)[46] |
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RTPI's 'review of 'Child-Friendly Planning in the UK ' concluded, the UK planning systems currently contain relatively little policy and guidance specific to children and young people." |
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The UN Committee on the Rights of the Child Concluding Observations (2016) notes that in the UK that children's views are not systematically heard on issues that affect them. It recommended that 'structures should be established for the active and meaningful participation of children and give due weight to their views in designing laws, policies, programmes and services at the local and national levels...' It went on to note that 'Particular attention should be paid to involving younger children and children in vulnerable situations, such as children with disabilities' and to 'Ensure that children are not only heard but also listened to and their views given due weight by all professionals working with children.' |
The UN Committee on the Rights of the Child Concluding Observations (2016) [48] |
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Decision making Around six in ten of young people surveyed (58 per cent) agreed that adults were good at taking their views into account when making decisions that affect them. This was an increase from 2017, when 53 per cent agreed.
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Young people's participation in decision making: attitudes and perceptions (2020)[49] |
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Use of Digital Communication Related to Age Nearly 9 in 10 adults (88%) in Scotland use the internet either for work or personal use, a steady increase over time from 65% in 2007. In 2019, almost all (99%) adults aged 16-24 reported using the internet, however the figure was much lower (43%) among those aged 75+. There is a clear relationship between age and internet use, with lower usage rates among older people. Although older adults were less likely to use the internet, the gap in internet use between adults aged 16-24 and adults aged 60 and above has fallen over time from 57 percentage points in 2007 to 35 percentage points in 2018. This result has mainly been driven by an increase in internet use amongst adults aged 60+ (from 29% to 65 %). The evidence suggests that using internet and social media are a good way of targeting young people but other ways of reaching and engaging older people may be more effective. |
| Characteristic : Disability | Source (full reference details in Appendix G) | Data gaps identified and action taken |
|---|---|---|
| Evidence gathered and Strength/quality of evidence | ||
Demographic Information Around one fifth of Scotland's population – approx. one million people – define themselves as disabled. |
National surveys and the census tells us about broad patterns of disability, but do not consider the implications of different types of disability in different contexts. |
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In 2011, the proportion of people in Scotland with a long- term activity-limiting health problem or disability was 20 per cent (1,040,000 people), the same proportion as reported in 2001 (1,027,872 people). |
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In 2012, 28 per cent of men and 35 per cent of women in Scotland reported a limiting long-term condition or disability. |
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For working-age adults, the percentage reporting a disability has not changed from 2018 to 2019 to 2019 to 2020, having remained at 19%. The percentage of children reporting a disability also remained stable at eight per cent over that two-year period. |
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The evidence gathered (above) from national surveys and similar suggests that a high percentage of households in Scotland have someone who is disabled or has a long-term health condition. |
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Outdoor Recreation A quarter of adults in Scotland (1.1 million people) state that their ability to participate in outdoor recreation is limited by a long-term illness, health problem or disability. |
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Challenges faced by blind or visually impaired park users London Borough of Richmond Council's Parks Team carried out a consultation to understand how blind people or those with visual impairments and their families / carers currently use their parks. It identified barriers to Visiting Parks Problems with parks infrastructure (e.g. paths, steps) was mentioned by 38% of respondents. Other things that were identified as hazards for blind and visually impaired park users were:
Other barriers identified by respondents included:
Views were also sought on how accessibility could be improved for people who are blind or visually impaired
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'Friendly Parks for All' consultation Challenges faced by blind or visually impaired park users. Consultation key findings March 2020, London Borough of Richmond Upon Thames[56] |
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Access to greenspace When asked if they live within 5 minutes' walk of their nearest green or blue space 66.98% of those without a limiting long term health condition responded they did, compared to 61.1% of those with a limiting long term health condition. |
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Nearly two thirds of respondents to a Scottish Youth Parliament survey with a disability or access requirement (aged 12-25) said they did not feel comfortable using public transport. This has an impact on their ability to access leisure and cultural activities outwith their immediate local area. |
All aboard: Young people's views and experiences of public transport in Scotland, (2019) [58] |
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Mobility and Accessibility - Inclusive Greenspace The accessibility to and within open spaces and play spaces is a critical design factor with regard to people with disabilities and health issues affecting mobility. "In order to optimise use for people, greenspace must be both accessible and worth visiting. Good accessibility is fundamental although there has, in the past, been a tendency towards an exclusive focus on one or two forms of disability (for example wheelchair users) and the physical aspects of site design (ramps and paths). However, accessibility is also to do with other factors such as distance from home and sociocultural factors - do people want to go there and do they feel safe and comfortable there? Social factors are sometimes overlooked but are often very significant in making people with disabilities feel excluded from landscape." The main barriers in using greenspace include:
Physical accessibility does not always equate with motivation to visit. The 'if we build it, they will come' method does not always succeed if the greenspace itself has previously been underused, or if the access works destroy the character of the place. Consulting with users and non-users of the space is key in finding out what people want to see there (engaging with stakeholders, the key people who may live or work near/around the park, local hospitals, schools, libraries, services, etc.) and is fundamental to be able to develop a sustainable solution. To make a space accessible it is vital that the policy adopted is one of integration not segregation. Sometimes well-intentioned spaces are designed or redesigned with the subtext of 'design for disability'. Inclusive greenspace strategies are best planned with all people in mind, not to reinforce feelings of difference, but instead to ensure that as many people as possible can enjoy the space, regardless of ability. |
Inclusive Greenspace, Sensory Trust[59] |
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Feeling unsafe outside Girls aged 7 to 21 who identify as having a disability are more worried about being outside alone (53%) compared to girls not identifying as having a disability (33%). |
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Inclusive Play The Report by the Scottish Alliance for Children's Rights on the State of Children's Rights in Scotland, highlights that children with disabilities are often excluded from leisure and play activities with their peers. This is often as a result of multiple barriers and intersections between poverty, disability, disadvantage, and inaccessible environments. |
Playing with quality and equality: a review of inclusive play in Scotland[61]. |
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Autism and greenspace Current evidence, though limited, suggests that engagement with the natural environment can be beneficial for children on the autistic spectrum. This reflects the fact that: (i) there is strong evidence that outdoor activities can benefit children in general; (ii) there is considerable evidence that outdoor learning is particularly helpful for children with Special Educational Needs (SEN) who often face more difficulties with classroom learning and greater barriers to accessing the outdoors. |
Engaging children on the autistic spectrum with the natural environment: Teacher insight study and evidence review (NECR116), Natural England, 2013[62] |
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Another study found that outdoor activities provide seven main benefits to children with autism, including promoting communication, emotion, cognition, interaction, physical activity, and decreasing autistic sensitivity. |
The Benefits of Outdoor Activities for Children with Autism, Chang, Yuan-Yu & Chang, Chun-Yen. (2018) (Sourced from the Children's Wood, below) |
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The Chang & Chang study supports anecdotal observations of the impact of nature on children and young people with autism. This also fits with observations at the Children's Wood where quite obvious positive changes in behaviour, stress levels, communication and sociability of children with autism were noticed. |
Benefits of Nature for Children with Autism , Children's Wood[63] |
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Learning disabilities Together's members have reported that bullying in public places is a significant barrier in accessing play for children with learning disabilities. |
Children's Rights: Consultation on incorporating the UNCRC into our domestic law in Scotland, The Scottish Commission for Learning Disability (2019) [64] |
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Loneliness levels amongst disabled people Disabled people were more than twice as likely to experience loneliness as non-disabled people. |
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Mental Health & Greenspace The link between green space and well-being is well established. Studies have shown that people experience less mental distress, less anxiety and depression, greater well-being and healthier cortisol levels (the hormone that controls mood) when living in urban areas with more green space compared with less. |
Mental Health And Town Planning (RTPI) Practice Note, 2020[66] |
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The benefits of green and open space to people's mental health and wellbeing became very evident during the Covid-19 pandemic. Almost three-quarters (70%) of people surveyed felt spending time outdoors in nature in 2020 helped them to de-stress, relax and unwind, and 56% agreed that it improved their physical health. |
| Characteristic – Sex / Gender | Source (full reference details in Appendix G) | Data gaps identified and action taken |
|---|---|---|
| Evidence gathered and Strength/quality of evidence | ||
Demographic Information Scotland had a relatively even split between genders in 2018, with 51% females and 49% males, although this varied amongst age groups. The youngest age groups had a higher male to female ratio as more male babies are born than female, whilst the oldest age groups had a lower male to female ratio as females have longer life expectancy in Scotland[68]. |
Mid-2018 Population Estimates Scotland (2019) |
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There is also a higher ratio of females to males in older ages, reflecting the longer life expectancy of females. |
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Access to greenspace In 2014 more men than women reported living within a 5-minute walk of their nearest green or blue space - 70.5% of men, compared to 66.7% of women. By 2019 this gender gap had narrowed with 65.2% of women and 65.9% of men living within a 5-minute walk. |
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In a survey conducted by Young Women Lead 2021 of women and non-binary people, 56% of respondents indicated proximity as their main reason behind the choice of what park they attend on a regular basis. Respondents noted that the level of convenience was relative to the proximity of the park to their home, work, or amenities, including events spaces, bars, and coffee shops. |
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Men's Health and link to greenspace Male cardiovascular disease and respiratory disease mortality rates decreased with increasing green space. Research has found that for men the risk of cardiovascular and respiratory disease mortality decreased with increasing green space coverage and was lowest for the greenest. Thus, men living in the greenest urban wards in the UK had a 5% lower risk of cardiovascular disease mortality and 11% lower risk of respiratory disease mortality than men in the least green wards. |
Gender differences in relationships between urban green space and health in the United Kingdom, The University of Edinburgh (Richardson, EA & Mitchell, R 2010)[72] |
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Women's use of Greenspace Women are under-represented in their use of green space, proportionate to their numbers in society. Women's use of urban green space may be influenced by the quality of the green space to a greater degree than men's. Women are less likely to engage in vigorous activity while there (Cohen, McKenzie, Sehgal et al, 2007). Certain social, physical and psychological barriers to access and participation have been identified for women, whether real or perceived (Ward Thompson, Bell, Satsangi et al., 2003). O'Brien (2005) reported that women have particularly acute concerns about their personal safety when visiting green spaces on their own. Foster, Hillsdon & Thorogood (2004) found that women were significantly less likely to undertake any walking if they perceived their local environment to have a low level of personal safety, whereas men's walking was not influenced by such concerns. Women report feeling safer in obviously managed areas, and have a significantly higher preference for visible management and law enforcement than males (Ho, Sasidharan, Elmendorf, Willits, Graefe, & Godbey, 2005; O'Brien, 2005; Virden & Walker, 1999). In contrast women feel more uncomfortable in neglected and abused areas, and have a significantly lower preference for remote natural settings than men (O'Brien, 2005; Virden & Walker, 1999). |
Gender differences in relationships between urban green space and health in the United Kingdom, (as above) |
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Women And Planning II highlights "The health implications for women and girls associated with the gendered use of public space was examined in a study conducted by Perez-Tejera et al (2018) of park use in Barcelona. The study found that more males than females frequented public open space overall. Of the women who were observed using public open space, they were more frequently observed in groups with children and elders and utilising playground facilities. Conversely, more males occupied public parks either as individuals or with groups of people of the same age. Males were also observed engaging in a greater range of activities compared to females (such as a variety of sporting activities, relaxing, picnicking and chatting)." |
Women And Planning II[73] (RTPI) (2021) |
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Girls use of parks A survey undertaken by Girl Guides Scotland, showed that 18% of girls felt unsafe going to the park by themselves. |
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Girls in Scotland (2020) notes that 31% of girls said they sometimes feel unsafe when spending time outside, and they're more likely to feel this way as they get older. Girls in Scotland (2020) reports 'most girls in Scotland lead an active lifestyle. However 'when it comes to sport and play, girls in Scotland feel constrained by gender stereotypes from a very young age'. |
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Make Space for Girls, who campaigns for facilities and public spaces for teenage girls, claims that "parks, play equipment and public spaces for older children and teenagers are currently designed for the default male." They have found evidence how girls are crowded out of parks and equipment, and how their needs are mostly ignored. It notes for example that "Academic research is consistently clear that skate parks are highly male places" A survey found that survey skate park use suggested that 90% of those who used a park in Nottingham were male. The Report notes 'Where the skate park is part of a wider landscape of park and leisure equipment, it's possible that a skate park could actually make the environment worse for girls, by bringing in boys from outside the area. One thing that is clear from the consultations and reports is that boys, particularly older ones, are willing to travel some distance to use a skate park which is larger or better than their local facility. In which case the local girls will face an even more intimidating atmosphere in their local park". The research notes "Yet skate parks are commonly seen as 'good' provision for all young people, and being expensive to build, also take up a very considerable share of any overall budget". |
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Use of playspaces by gender "'Places for Girls', White Arkitekter's research project into inclusive public spaces was kick-started by some unsettling statistics from predominantly gender-equal Sweden: while use of play spaces may be equally split across genders in the younger age groups, in park space planned for teenagers a disturbing disparity begins to emerge, with use among young people reflecting an 80/20 boy-girl gender imbalance, and youth club spaces exhibiting a similar split of 70/30." |
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Facilities / toilets In the research report Glasgow : A Feminist City it notes that the data gathered highlighted failures in the provision of public services, particularly public toilets within parks, that have a consequence on the ease of day-to-day city living for women and non-binary people. This report noted that the lack of public toilets was a factor leading to women and non-binary people feeling uncomfortable in Glasgow Parks. 55.4% highlighted that there were no toilets in the park they most frequently visited, and 35.8% of participants indicated that the provision of more toilets would encourage them to visit parks more frequently and for longer periods of time." "When asked how an individual would improve public parks in general, 78% of respondents answered free public toilets." "This highlights that although people want to enjoy public open spaces, they are unable to stay for as long as they might because they need the toilet. More public toilets would encourage people to spend more time outdoors, and make Glasgow parks more accessible in general." |
Glasgow: A Feminist City? |
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Safety Over a quarter (26%) of girls aged 7 to 10 feel unsafe when they go outside, increasing to two fifths (41%) for those aged 11 to 16, and almost half (49%) aged 17 to 21. Additionally, a third (34%) of girls aged 7 to 21 say they feel worried to do things outside on their own. Almost one in ten girls aged 7 to 10 say they are often stared at and receive unwanted attention when they're outside, increasing to almost a quarter (22%) for those aged 11 to 16, and rising to 41% for young women aged 17 to 21. |
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"Safety isn't just something which teenage girls worry about; often adults see parks and public spaces as dangerous spaces for girls and so forbid them from going there or move them on. Girls, as one academic described it, are seen as being the 'wrong' gender in the 'wrong' space." "Surveillance is also important in helping girls feels safe, and so the presence of play workers and park staff can also be a big factor in creating parks which are used by girls more equally, but this is an expensive solution and so not generally feasible". |
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Just over a fifth (22%) of all girls and young women say fear of harassment stops them taking part in activities they enjoy, like running or walking outside. This is particularly true for those aged 17 to 18 (38%) compared to girls aged 13 to 16 (13%), and for girls of colour (32% compared to 19% of white girls). |
Research briefing: It happens all the time Girls' and young women's experiences of sexual harassment, GirlGuiding[80] |
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According to a survey of women and non-binary people in Glasgow only 20% of all 214 participants who provided a response to this question felt very comfortable in their chosen park. This highlights that while these spaces are invaluable to many and serve multiple purposes, safety is a major issue for the majority of visitors. There was a strong consensus for reasons behind why women and non-binary people feel uncomfortable, especially when visiting at night. The key factors that emerged were: inadequate lighting, increased use of alcohol and drugs by other people in the park and a heightened risk of assault, harassment, abduction or even murder. Many of the women and non-binary people surveyed indicated that they simply did not visit parks at night, beginning as early as dusk/sundown. Several shared stories of negative experiences of being there after dark, or stories and incidents that cautioned them against visiting parks at night. |
Glasgow: A Feminist City? |
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Design and Layout Make Space for Girls sets out some ways of dealing with inequality in access to spaces, that councils, planners and designers can consider. It notes that there are proven ways to improve the design of existing parks to make them more welcoming to girls, and to prevent boys from dominating the spaces, including:
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Women In Planning II notes "the design of many of our public spaces has failed to consider the different ways they are used by men and women. Design decisions such as the type of sporting facilities offered in public parks, the frequency of benches, the presence of playgrounds and the installation of appropriate lighting all play a role in the use of public spaces by women and girls." |
Women And Planning II[81] (RTPI) (2021) |
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Physical Activity & Participation in Physical Activity & Sport A higher proportion of men met the MVPA (Moderate-to-Vigorous Physical Activity) guidelines than women (51% compared with 42% respectively). |
Scottish Health Survey (2020)[82] |
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Participation rates in physical activity and sport were higher among men than women (82% and 78% respectively). |
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Gender differences are more pronounced for particular types of physical activity and sport. This difference was larger when excluding walking (58 and 49 per cent respectively). The most common activity was recreational walking, with similar level of participation for both men and women participating at around the same level (69 and 71 per cent respectively). |
Scotland's People Annual Report: Results from 2017 Scottish Household Survey (2018) (section 8.2.4)[84] |
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Lone parents The large majority of lone parent households are headed by women and these households tend to experience high poverty rates: 34% were in poverty in 2014/15, compared with 26% of single working age women without children. For comparison, 16% of couples with dependent children were in poverty in 2014/15. These statistics have implications for child poverty, as women tend to be the main carers of children. |
Sourced from the Equality Impact Assessment for the Child Poverty (Scotland) Bill[85] |
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Lone mothers make up a quarter of all families with children in the UK, about 2 million families with 3.2 million children (ONS, 2015; Klett-Davies, 2016). Lone parent households often suffer from demanding schedules, which have an impact on family time. For households who are particularly "time poor" the need to be able to access play opportunities in close proximity to homes may have increased importance. |
Work and Relationships Over Time in Lone-mother Families, 2017, Joseph Rowntree Foundation [86] |
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Participation of women in engagement on the built environment Women can find it more difficult to engage in planning processes since they are more likely to provide unpaid care and the timing and places of consultation may not recognise caring responsibilities. Women from some minority ethnic groups may not wish to attend mixed gender consultation meetings. Studies by the Women's Design Service show an under-representation of disabled women in consultation processes. |
Royal Town Planning Institute, Good Practice Note 7: Gender and Spatial Planning (2007)[87] |
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Women in Planning II argues for the incorporation of gender mainstreaming into all policy, legislative and decision-making practices. |
Women And Planning II[88] (RTPI) (2021) |
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Engaging girls / young women on the type of facilities they want Make Space for Girls highlights the importance of asking girls what they want and provide facilities which they are interested in and will use. It says, "Only by doing this can councils, designers and planners find out what girls want from parks, and what the problems are with the current provision and girls do want to be involved." |
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The majority (82%) of girls and young women aged 7 to 21 think that children and young people should be more involved in designing playgrounds, parks and outdoor facilities in their local area, and almost half (48%) would like more to be done so that girls and young women can feel safe outside. |
Girls Attitudes Survey 2020, GirlGuiding[89] |
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Internet use Overall there was no significant difference in use of internet between genders. |
Scottish Household Survey 2018: annual report (2018)[90] |
| Characteristic: Pregnancy and Maternity | Source (full reference details in Appendix G) | Data gaps identified and action taken |
|---|---|---|
| Evidence gathered and Strength/quality of evidence | ||
Numbers In 2019 there were 49,863 live births recorded across Scotland, slightly fewer than in 2018. |
We will consider any views expressed in the consultation responses about any effects on people because of pregnancy and maternity. |
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Greenspace and Improved pregnancy outcomes "There is considerable evidence of beneficial effects of access to green space for the health of pregnant women. Specifically, studies in Europe showed positive associations between access to nearby green space and both reduced blood pressure and reduced depression in pregnant women, with a stronger effect for reduced depression in disadvantaged groups." Research shows that access to green space in close proximity to the homes of pregnant women was positively associated with birth weight. Birth weight is a useful indicator of health in early life: low birth weight is one of the major predictors of neonatal and infant mortality, as well as long‐term adverse effects in childhood and beyond. Recent studies also found a positive association between residential greenness measured and birth weight. A report by the World Health Organisation comments "The evidence shows that urban green space has health benefits, particularly for economically deprived communities, children, pregnant women and senior citizens. It is therefore essential that all populations have adequate access to green space, with particular priority placed on provision for disadvantaged communities. While details of urban green space design and management have to be sensitive to local geographical and cultural conditions, the need for green space and its value for health and well‐being is universal." |
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Link between green space and depressive symptoms in pregnant women 7547 women recruited to the 'Born in Bradford' cohort completed a questionnaire during pregnancy. A binary measure of depressive symptoms was calculated using a validated survey. Two green space measures were used: quintiles of residential greenness calculated using the normalised difference vegetation index for three neighbourhood sizes (100, 300 and 500 m buffer zones around participant addresses); access to major green spaces estimated as straight line distance between participant address and nearest green space (>0.5 hectares). Pregnant women in the greener quintiles were 18-23% less likely to report depressive symptoms than those in the least green quintile (for within 100 m of green space buffer zone). The green space-depressive symptoms association was significant for women with lower education or who were active. Physical activity partially mediated the association of green space, but explained only a small portion of the direct effect. The research finds that 'Higher residential greenness was associated with a reduced likelihood of depressive symptoms. Associations may be stronger for more disadvantaged groups and for those who are already physically active. Improving green space is a promising intervention to reduce risk of depression in disadvantaged groups.' |
National Library of Medicine[93] |
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Need for Seating Pregnant women may also find standing difficult and need facilities to sit down. |
| Characteristic: Sexual Orientation | Source (full reference details in Appendix G) | Data gaps identified and action taken |
|---|---|---|
| Evidence gathered and Strength/quality of evidence | ||
Demographic Information Evidence suggests that there are in the region of 2% of people in Scotland who identify as LGBO (Lesbian, Gay, Bisexual, Other). |
The Sexual Orientation in Scotland 2017: summary of evidence base[95] |
We will consider any views expressed in the consultation responses on whether the provisions are likely to have any disproportionate effects on people due to their sexual orientation. |
Health LGBO adults were less likely than heterosexual adults to report good general health. Only 71% of LGBO adults recorded good or very good health compared to 75% of heterosexual adults. And 10% of LGBO adults recorded bad or very bad health compared to 7% of heterosexual adults. In 2015, LGBO adults had lower mental wellbeing than the heterosexual group - a score of 23.5 compared with 24.4. |
The Sexual Orientation in Scotland 2017: summary of evidence base[96] |
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Planning As a whole, this group had no special needs or requirements when it came to planning. Their views were representative of the general population. |
Consultation on the Modernisation of the Planning System with 'seldom heard' Groups (2009)[97] |
|
Access and use of play and open spaces LGBT children and young people may be significantly disadvantaged in accessing adequate play, leisure and culture opportunities. |
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In a survey of 684 LGBT children and young people (aged 13-25), less than half said there were enough places where they could safely socialise and be open about their sexual orientation and gender identity. This was a particular issue for transgender and non-binary people, of whom less than one third said there were enough places where they could socialise safely. |
Life in Scotland for LGBT Young People, LGBT Youth (2018)[99] |
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"LGBTQ+ people 'switch' or hide their identities in order to feel safe in the majority of public spaces." "Despite the emergence of queer enclaves in many cities across the world in recent decades, there is an urgent need today to rethink public spaces and create more inclusive, welcoming and hospitable environments for all members of our communities." "Avoiding over-designing spaces was something of a theme both in the literature and in the comments of our respondents. Design should be on a human scale as one respondent put it, but not a scale which sees the default human as male, heterosexual, cisgendered, middle-class and white. Instead, examples of spaces regarded as queer-inclusive were ones which had a diverse feel to them. These were not uniform in terms of scale and mass of buildings, rooflines, colour or facades. They were not rectilinear and offered a range of sightlines through spaces which were punctuated by features. Their soundscapes were softened by greenery or bodies of water, rather than harshened by hard surfaces. Space was not open and intimidating but broken up and intimate." |
Queering Public Space Exploring the relationship between queer communities and public spaces[100] |
| Characteristic : Gender Reassignment | Source (full reference details in Appendix G) | Data gaps identified and action taken |
|---|---|---|
| Evidence gathered and Strength/quality of evidence | ||
In a survey, less than one third of transgender and non-binary people said there were enough places where they could socialise safely. |
Life in Scotland for LGBT Young People LGBT Youth (2018). [101] |
We will consider any views expressed in the consultation responses on whether the provisions are likely to have any disproportionate effects on people under the gender reassignment protected characteristic. |
54% of trans respondents avoided being open about their gender identity in 'the park' for fear of a negative reaction from others. |
National LGBT Survey Research Report (Government Equalities Office) 2018[102] |
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Accessibility & convenience In a survey conducted by Young Women Lead 2021 of women and non-binary, 56% of respondents indicated proximity as their main reason behind the choice of what park they attend on a regular basis. Respondents noted that the level of convenience was relative to the proximity of the park to their home, work, or amenities, including events spaces, bars, and coffee shops. |
Glasgow: A Feminist City? |
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Facilities / toilets In the research report Glasgow : A Feminist City, it notes that the data gathered highlighted failures in the provision of public services, particularly public toilets within parks, that have a consequence on the ease of day-to-day city living for women and non-binary people." This report noted that the lack of public toilets was a factor leading to women and non-binary people feeling uncomfortable in Glasgow Parks. 55.4% highlighted that there were no toilets in the park they most frequently visited, and 35.8% of participants indicated that the provision of more toilets would encourage them to visit parks more frequently and for longer periods of time." "When asked how an individual would improve public parks in general, 78% of respondents answered free public toilets." "This highlights that although people want to enjoy public open spaces, they are unable to stay for as long as they might because they need the toilet. More public toilets would encourage people to spend more time outdoors, and make Glasgow parks more accessible in general." |
Glasgow: A Feminist City? |
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Feeling safe According to a survey of women and non-binary people in Glasgow only 20% of all 214 participants who provided a response to this question felt very comfortable in their chosen park. This highlights that while these spaces are invaluable to many and serve multiple purposes, safety is a major issue for the majority of visitors. There was a strong consensus for reasons behind why women and non-binary people feel uncomfortable, especially when visiting at night. The key factors that emerged were: inadequate lighting, increased use of alcohol and drugs by other people in the park and a heightened risk of assault, harassment, abduction or even murder. Many of the women and non-binary people surveyed indicated that they simply did not visit parks at night, beginning as early as dusk/sundown. Several shared stories of negative experiences of being there after dark, or stories and incidents that cautioned them against visiting parks at night. |
Glasgow: A Feminist City? |
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A higher percentage of girls and young women who identify as having a disability or identify as LGBQ feel unsafe when they go outside. Significantly, girls and young women aged 11 to 21 who identify as LGBQ are more likely to receive unwanted attention (46%) compared to those who don't identify this way (29%). |
Girls Attitudes Survey 2020, GirlGuiding |
| Characteristic : Marriage and Civil Partnership | Source (full reference details in appendix) | Data gaps identified and action taken |
|---|---|---|
| Evidence gathered and Strength/quality of evidence | ||
The Scottish Government does not require assessment against this protected characteristic unless the policy or practice relates to work, for example HR policies and practices. This policy does not relate to work therefore we have not considered it for this interim EQIA. |
N/A |
| Characteristic: Race | Source (full reference details in Appendix G) | Data gaps identified and action taken |
|---|---|---|
| Evidence gathered and Strength/quality of evidence | ||
Demographic Information In 2011 Scotland's population was 96.0% white, a decrease of 2.0% from 2001. 2.7% of Scotland's population (about 141,000 people) identified as Asian, Asian Scottish or Asian British. Just over 1% of Scotland's population (more than 36,000 people) identified as African, Caribbean or Black. In 2011, there were approximately 200,000 Black, Asian and Minority Ethnic (BME) people in Scotland, making up just over 4% of the population. BME communities are largely concentrated in urban locations. |
During the consultation period, we will seek views from representative organisations for on whether the proposals are likely to have any disproportionate effects on people due to their race. |
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Access to green or blue space In terms of living within a 5-minute walk of the nearest greenspace, there is a marked difference by ethnicity;
|
National Indicator Performance (data from Scottish Household Survey)[107] |
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Use of natural spaces "A health disparity is created by BME people's lower presence in nature and open countryside. A 2017 report from Natural England shows black and Asian people are less likely to regularly visit natural settings. There is wide recognition within the environmental field that participation within nature-based activities is largely white. This low presence matters because BME people miss out on the pleasure, health benefits and conservation of natural spaces." |
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Barriers to engagement Language barriers, lack of confidence and dominant characters can discriminate against some people during community engagement in minority ethnic groups, were noted as particularly experiencing these issues along with several other protected characteristic groups. |
Evidence would suggest that people wish to engage in planning though they are not always able to do so. |
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Some people from specific communities of interest and identity described finding it difficult to get involved in decisions, or having no experience of involvement at all. For example, some asylum seekers, EU citizens, foreign language groups, and some people from different ethnic minority groups described experiences of being detached from the wider community and formal decision-making organisations and forums. They did not know about local groups or understand whether and how they could get involved. |
Local Governance Review: analysis of responses to Democracy Matters (2019) [110] |
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In particular women from some minority ethnic groups may not wish to attend mixed gender consultation meetings. |
Royal Town Planning Institute, Good Practice Note 7: Gender and Spatial Planning (2007)[111]. |
|
Language barriers, lack of confidence and dominant characters can discriminate against some people during community engagement specifically women, minority ethnic groups, young and old people and people with disabilities. |
| Characteristic: Race Gypsy / Travellers | Source (full reference details in Appendix G) | Data gaps identified and action taken |
|---|---|---|
| Evidence gathered and Strength/quality of evidence | ||
Demographic Information Just over 4,000 people in Scotland identified in the census that their ethnic group was 'White: Gypsy/Traveller' and this represented 0.1 per cent of the population. Some organisations working with Gypsy/Travellers in Scotland estimate that the population figure is much higher. Census data provides some indication of the spatial distribution of the community. The council areas with the most Gypsy/Travellers resident on census day were Perth & Kinross, Glasgow City and the City of Edinburgh. The lowest numbers were resident in the island councils and in Inverclyde. |
Gypsy/Travellers in Scotland - A Comprehensive Analysis of the 2011 Census (2015)[112] |
We will actively seek views from representative organisations on whether the proposals are likely to have any disproportionate effects. |
Health In 2011 Gypsy/Travellers in Scotland, compared to the population as a whole, were more likely to report a long-term health problem or disability and were more likely to report bad or very bad general health. |
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Homes Gypsy/Travellers in Scotland, compared to the population as a whole, were: - less likely to own their home; - more likely to live in a caravan; - more likely to live in overcrowded accommodation. |
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Play Gypsy/Traveller children have reported a range of problems about residential sites, including unsafe playparks. |
Civil Society Report to inform the UN Committee on the Rights of the Child's List of Issues Prior to Reporting By Together (Scottish Alliance for Children's rights)[113] |
Scottish Government is developing Site Design Guidance for Gypsy Traveller Sites, which will be published in due course. |
| Characteristic : Religion or Belief | Source (full reference details in Appendix G) | Data gaps identified and action taken |
|---|---|---|
| Evidence gathered and Strength/quality of evidence | ||
Demographic Information Christian denominations represented the majority of the Scottish population (54%). 37% of the population stated they had no religion in 2011, an increase of over half a million people from 2001. The second largest religion was 'Muslim' which represented 1.4%, and the other religions combined (including 'Hindu', 'Buddhist', 'Sikh' and 'Jewish') represented a further 1%. 7% of people did not state their religion. |
Analysis of Equality Results from the 2011 Census (2014)[114] |
As part of the consultation, we will seek views on whether the provisions are likely to have any disproportionate effects on people of religion or belief. |
Access to green or blue space Those responding as having no religion or as Christian were more likely to live within 5 minutes of a greenspace compared to those belonging to another religion. 63.61% of Christians, compared to 48.09% of those from other religions indicated they lived within 5 minutes' walk of their nearest green or blue space. |
National Indicator Performance (data from Scottish Household Survey)[115] |
| Characteristic: Low Income / Poverty | Source (full reference details in Appendix G) | Data gaps identified and action taken |
|---|---|---|
| Evidence gathered and Strength/quality of evidence | ||
Demographic Information
|
As part of the consultation, we will seek views on whether the proposals are likely to have any disproportionate effects on people living on low income and/or living in poverty. |
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Child Poverty Poverty impacts all areas of a child's life, including nutrition, standard of living, relationships, social and emotional wellbeing, play and education. |
Civil society report to inform the UN Committee on the Rights of the Child's List of Issues Prior to Reporting By Together (Scottish Alliance for Children's rights)[118] |
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Health Inequalities The gaps between those with the best and worst health and wellbeing still persist, some are widening, and too many Scots still die prematurely. This is illustrated by the Glasgow train line map - Life expectancy in men goes down by two years for every station on the trainline travelling from Jordanhill (in the west end) to Bridgeton (in the east end). On average, a man born in Bridgeton can expect to live 14.3 years less than his counterpart in Jordanhill, and a woman 11.7 years less. NHS health Scotland recommended a number of key actions to prevent environmental factors causing health inequalities, to ensure equity including to ensure local service availability and high quality green and open spaces, including space for play. |
Health inequalities: What are they ? How do we reduce them? NHS Health Scotland[119] |
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Child obesity Children living in the most deprived areas were more than twice as likely to be obese than those living in the least deprived areas. |
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Access to greenspace at home – by tenure In relation to access to greenspace at home Public Health Scotland recent analysis was quoted as showing that there is quite a differentiation between space (private outdoor space at home e.g. gardens or balconies) depending on the tenure. Hansard reported that only 3% of homeowners do not have access to open space in the house, whereas for private sector tenants it is 23% and for local authority tenants it is 19%. |
Public Health Scotland, data quoted at House of Lords, Covid-19 Committee[121] |
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Access to play areas and greenspace People living in the most deprived areas are less likely to live within a 5 minute walk of their nearest greenspace than people in less deprived areas. This observation has been consistent over the time series the data has been collected. In 2019 for those in '20% most deprived' category, 62.11% reported living within a 5-minute walk of the nearest greenspace; this figure increased to 67.08% of those in the '20% least deprived' group. |
National Indicator Performance (data from Scottish Household Survey)[122] |
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Data published by ONS states "Parks are most accessible in the poorest areas, with people in the most deprived neighbourhoods of England around twice as likely as those in the least deprived to be within five minutes' walk of a public park (34% compared with 18%). Including playing fields, this rises to 57% compared with 42%. We see similar trends in Wales and Scotland, with greater access among those living in more deprived areas." |
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The 2016 Scottish Household Survey showed that most children had access to play areas in their neighbourhood, but that availability differed according to levels of deprivation within urban areas. Households within the 20% of most deprived urban areas said they had less access to a natural environment or wooded area in their neighbourhood, compared to the rest of urban areas. Parents living in the 20% most deprived urban areas were also much less likely to think that it was safe for children to travel alone to most play areas. |
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Quality of local greenspace More deprived areas often have more greenspace in terms of quantity, but it may be of poorer quality, not accessible or aesthetically poor. |
Greenspace, urbanity and health, Journal of Epidemiology and Community Health.[126] |
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Respondents living in the 15% most deprived areas of Scotland were more likely to agree or agree strongly that the quality of their local greenspace has reduced in the past 5 years (50% strongly agree/agree, compared to 40% of urban Scots) or if just use 'strongly agree' 26% compared to 18%. |
Greenspace Use and Attitudes Survey 2017 greenspace scotland (2017) [127] |
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Previous research found that the quality of play areas was poorer in more deprived neighbourhoods, as compared to those in the least deprived areas. |
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Covid - visits to greenspace "Green space positively influences health and well-being; however, inequalities in use of green space are prevalent. Movement restrictions enforced due to the COVID-19 pandemic could have exacerbated existing inequalities regarding who visits green space." "Lower social grade respondents reported little or no change in visitation to green space, with time spent visiting green space remaining low both before and after movement restrictions were enforced. This is supported by previous studies exploring the association between socio-economic position (SEP) and green space use. One possible explanation is a lack of interest in visiting green space reported by lower SEP individuals." |
Change in time spent visiting and experiences of green space following restrictions on movement during the COVID-19 pandemic, BMJ[128] |
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Use of green and open space Research published by Public Health Scotland finds that 'Socio-economic inequalities in use of green and open spaces existed before lockdown. Lockdown did not reduce these and may have made them worse.' It also notes that users reported that green and open space benefited their mental health during lockdown. Individuals of higher social grade were more likely to report increases in use, and also greater benefits to their mental health. |
'Change in use of green and open space following COVID-19 lockdown 'stay at home' phase and initial easing of lockdown' Public Health Scotland[129] |
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Child Poverty – impact on play Children living in poverty are more likely to be solitary, play alone and be bullied frequently. |
Civil society report to inform the UN Committee on the Rights of the Child's List of Issues Prior to Reporting By Together (Scottish Alliance for Children's rights)[130] |
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Participation in physical activity and sport (including recreational walking) was lower for those living in the most deprived areas (70%) compared to the least deprived areas (90%). Participation in walking (for at least 30 minutes) was also lower for those living in the most deprived areas (57%) compared to those living in the least deprived areas (78%). |
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'sedentary time tends to be higher in deprived areas' 'physical activity levels tend to be lower in deprived areas' |
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Internet Use and Income Level Gaps in internet access and use remain amongst certain groups including those in deprived areas, those in social housing and those on low incomes. 23 per cent of adults living in the 20 per cent most deprived areas in Scotland reported not using the internet compared with 15 per cent in the rest of the country. Home internet access varies with household income, although the gap is lessening over time. In 2016, 63 per cent of households with incomes of £15,000 or less had home internet access, increasing to 98 per cent of households with incomes over £40,000. Among those that have internet access, a lower proportion of adults in social housing were confident in their ability to use the internet than those in private rented housing and those who own their own homes. Those aged over 45 and those on incomes between £6,000 - £20,000 consistently reported being less confident than average. The evidence indicates that internet access and confidence in using it varies by tenure and household income. |
Stage 3: Assessing the quality of the impacts and identifying opportunities to promote equality
At this stage of the interim equality impact assessment, the qualitative scoring of the potential impacts (negative, positive and neutral) have been considered for each of the protected characteristics and the other specified characteristics already listed in this interim EQIA. This qualitative scoring has been undertaken using the data and evidence available and gathered to date. This is a preliminary and indicative assessment of the potential impacts at this interim stage of the EQIA and will be subject to further review and revision after the consultation has taken place and during the finalisation of the Regulations and any future guidance.
Do you think that the policy impacts on people because of their age?
Age:
Eliminating unlawful discrimination, harassment and victimisation
Positive X
Negative
None
Reasons for your decision:
The draft Regulations should, after consultation, be designed in such a way that they will not create unlawful discrimination related to age.
The draft OSS Regulations require that in discharging their duties to prepare an OSS planning authorities are to consider how the open space strategy will contribute to a series of outcomes including
- advancing equality and eliminating discrimination,
the policy aim behind this is to ensure good access to greenspace for all.
The aim is to provide opportunities for engagement for all sectors of society, with requirements to consult children, and the wider public (which should cover older age groups).
Age:
Advancing equality of opportunity
Positive X
Negative
None
Reasons for your decision:
The Planning (Scotland) Act 2019 sets out PSAs are to consider whether there are sufficient opportunities for children to play. The draft Regulations go on to require planning authorities to identify play opportunities for all ages of children.
We encourage planning authorities to consider if they may wish to refer to demographic data on the children in their areas, including data on the number of children in different prescribed age groups to ensure their assessments take account of the needs of different ages of children. Data is available from NRS.
Evidence shows levels of overweight/obesity between children increased with age. So it is important that older children have good opportunities to play and be physically active. Shared good practice and guidance will provide more detail on the different types of play opportunities which may be enjoyed by different ages of children. Plus, the expectation is that by consulting with children in the preparation of the PSA, that this will help identify the needs of different ages of children, locally, through hearing directly from children of different ages the types of play spaces and opportunities they enjoy.
The evidence shows that children frequently want 'lots of green spaces' and 'more places to play'. Both sets of draft regulations require planning authorities to consider the 'quantity' of open space, and play opportunities, respectively, on a locality basis, this will help inform local authorities on the amount of open space and places to play within local neighbourhoods.
We understand that both young children and older people may have difficulties walking or travelling longer distances. 'Accessibility' has been included in both sets of draft Regulations as an aspect that planning authorities would be required to provide information on. By ensuring planning authorities consider how accessible open spaces and play opportunities are should help people on both ends of the age spectrum.
The degree to which people said they felt a very strong or fairly strong sense of belonging to their community varied by age, it reveals 87% for those aged 75 and above compared to 73% of those aged between 16 and 24. Provisions that help improve the quality of places and neighbourhoods, including quality open spaces and play opportunities, could reasonably be predicted to have a positive impact on people's sense of neighbourhood generally, and particularly for young people. Quality is an aspect that both sets of draft Regulations require planning authorities to consider and provide information on.
The evidence suggests that the majority of young people feel they should be involved in planning in their local area and that their local councils should look at ways to support children and young people to do this. The draft PSA Regulations provide opportunities for different ages to engage in the assessment. They require planning authorities to consult, amongst others; children, parents and carers, community councils and the public when preparing the PSA. The draft OSS Regulations also require specifically planning authorities to consult children and young people, and older people, as well as community councils and the public generally, to help ensure that the views of all ages are sought.
In addition, to help ensure equality of opportunity for younger age groups in terms of engagement, we suggest that planning authorities may wish to publish alongside the main documents (PSA and OSS respectively), a child friendly version.
The evidence shows that there is a clear relationship between age and internet use, with lower usage rates and accessibility among older people and higher use among younger people. This suggests that using internet and social media are a good way of targeting young people but other ways of reaching and engaging older people may be more effective. In response the draft OSS Regulations contain a provision requiring planning authorities to publicise the consultation on their draft OSS using adverts in the local press, to help ensure more older people have the opportunity to offer their views on the draft open space strategy.
Age:
Promoting good relations among and between different age groups
Positive X
Negative
None
Reasons for your decision:
Play expert Tim Gill notes 'the presence of children playing in the street can be seen as a litmus test of the level of community cohesiveness in a neighbourhood: if significant numbers of parents feel it is safe enough to let children of different ages play out, that is a good sign that the street and the neighbourhood as a whole is a place where children will be watched over and cared for, and where residents feel a sense of belonging. This is not to say that everyone is unconditionally positive about children playing in the street, or that problems will never arise. Indeed low-level conflict between children and adult residents is quite likely to occur, just as it has in the past."
Both sets of draft Regulations require planning authorities to consult children and the public, the draft PSA regulations also require them to consult parents and carers - this will ensure all ages can be involved. This should ensure planning authorities will be informed of the specific needs of local children and help encourage children to participate in public life where their participation is currently disproportionately low.
The draft PSA Regulations require planning authorities to assess play opportunities for children of all ages, this should promote good relations amongst different age groups of children, ensuring all children are able to access play opportunities and prevent exclusion for certain age groups.
Open space strategies and play sufficiency assessments could potentially promote good relations between different age groups by helping to ensure there are enough different types of quality open spaces and places to play in communities. This could help ensure that young people have enough things to do and places to go, rather than potentially be drawn into more anti-social activities, which could disturb older people. This could also help in terms of the wider 'prevention' agenda.
By including 'quality' in the draft Regulations as key components of Open Space Strategies and Play Sufficiency Assessments, it is hoped this will help drive action to improve the quality of open spaces and play opportunities within communities. People from all age groups could, as a whole community, collectively view and take pride in their neighbourhood from a more positive perspective.
Do you think that the policy impacts people with disabilities?
People With Disabilities:
Eliminating unlawful discrimination, harassment and victimisation
Positive X
Negative
None
Reasons for your decision:
The draft Regulations should, after consultation, be designed in such a way that they do not create unlawful discrimination related to disability.
The draft OSS Regulations require that in discharging their duties to prepare an OSS planning authorities are to consider how the open space strategy will contribute to a series of outcomes including
- advancing equality and eliminating discrimination,
the policy aim behind this is to ensure good access to greenspace for all.
People With Disabilities:
Advancing equality of opportunity
Positive X
Negative
None
Reasons for your decision:
The evidence from national surveys and similar suggests that a high percentage of households in Scotland have someone who is disabled or has a long-term health condition. The draft OSS Regulations require that in discharging their duties to prepare an OSS planning authorities are to consider how the open space strategy will contribute to the outcome of 'improving health and wellbeing'.
The accessibility of open spaces and play opportunities is vital in terms of advancing equality of opportunity for people with disabilities and health issues affecting mobility.
Both sets of draft Regulations require planning authorities to provide information on 'Accessibility', this should help to ensuring planning authorities consider how accessible open spaces and play opportunities are. Shared good practice and guidance will provide more advice to planning authorities about what they should be considering in relation to accessibility, both in terms of getting there, and the proximity of spaces to homes and their location within neighbourhoods, as well as accessibility within the spaces once there in terms of the path network etc. Shared good practice and guidance may also expand on the concept of accessibility and planning for inclusive open spaces and play opportunities in terms of design and provision of facilities etc.
The Sensory Trust advises consulting with users and non-users of the space is key in finding out what people want to see there and that inclusive greenspace strategies are best planned with all people in mind.
Both sets of draft Regulations aim to advance equality of opportunity to engage in the assessments (the Open Space Strategy and Play Sufficiency Assessment).
The draft OSS Regulations require planning authorities to, in carrying out the open space audit, seek the views of and have regard to any views expressed by disabled people. They are also to seek and have regard to their views when carrying out an assessment of current and future open space requirements. It is proposed planning authorities will be required to consult with people with disabilities on the draft open space strategy and have regard to any valid representations, with provision for planning authorities to be able to modify the draft to take account of timeous representations, before publishing the final Open Space Strategy.
The draft PSA Regulations also require planning authorities to consult children and their parents and carers when preparing the play sufficiency assessment. Through this consultation, planning authorities will be able to be informed of the specific needs of local children, including those with disabilities.
People With Disabilities:
Promoting good relations among and between disabled and non-disabled people
Positive X
Negative
None
Reasons for your decision:
The intention behind the regulations and any future guidance is to ensure planning authorities cater for more inclusive design and facilities of open spaces and play spaces to enable people and children with disabilities to access them and use them alongside non-disabled people and children.
Do you think that the policy impacts on men and women in different ways?
Sex/Gender:
Eliminating unlawful discrimination, harassment and victimisation
Positive X
Negative
None
Reasons for your decision:
The draft Regulations should, after consultation, be designed in such a way that they do not create unlawful discrimination related to gender.
The draft OSS Regulations require that in discharging their duties to prepare an OSS planning authorities are to consider how the open space strategy will contribute to a series of outcomes including
- advancing equality and eliminating discrimination,
the policy aim behind this is to ensure good access to greenspace for all.
Sex/Gender:
Advancing equality of opportunity
Positive X
Negative
None
Reasons for your decision:
Evidence shows women are under-represented in their use of green space, proportionate to their numbers in society, and their use of urban green space may be influenced by the quality of the green space to a greater degree than men's.
For the individual open spaces included in the open space audit, the draft OSS Regulations set out that the audit may include information about the function of the open space and the extent to which it delivers those functions – this is seen as having a quality i.e. how well the space delivers on its functions and is fit for purpose. The draft OSS Regulations require open space audits to include a statement on the quality of the open spaces and green networks in respect of each locality within their area, and for the totality of their area. Shared good practice and guidance will provide more detail on the types of considerations that contribute to quality, this is likely to link to the qualities of successful places set out in national planning policy, including being 'safe and pleasant'.
The evidence suggests women are likely to have greater concerns about their personal safety travelling to / from and within parks and green spaces. For the individual open spaces included in the open space audit, the draft Regulations set out that the audit may include information on the accessibility to the public. The draft OSS Regulations require open space audits to include a statement on the accessibility of the open spaces and green networks in respect of each locality within their area, and for the totality of their area. As indicated above shared good practice and guidance will provide more details, and how to link to the qualities of successful places set out in NPF, including being 'safe and pleasant'.
The large majority of lone parent households are headed by women. Lone parent households can often suffer from demanding schedules, which have an impact on family time. Potential mitigation of this issue is to ensure that those who are 'time poor' have convenient access to open spaces and play opportunities to take children to. Both the draft OSS and PSA Regulations require planning authorities to consider the accessibility of open spaces and green networks and play opportunities respectively.
Evidence shows that boys and girls play in different ways, especially as they grow older. Make Space for Girls highlighted how girls are crowded out of parks and equipment, and how their needs are mostly ignored and that parks, play equipment and public spaces for older children and teenagers are currently designed for the default male. Provision is almost entirely in terms of skate parks, BMX tracks, football pitches and MUGAs, which are used almost entirely by boys. Future shared good practice and guidance may highlight more details on considerations around gender issues, the need to consult with girls and boys and look for any patterns of exclusion that needs to be addressed, to ensure appropriate provision for both girls and boys is available locally.
In terms of engagement the evidence notes that women can find it more difficult to engage in planning processes since they are more likely to provide unpaid care and the timing and places of consultation may not recognise caring responsibilities, and women from some minority ethnic groups may not wish to attend mixed gender consultation meetings. We have taken the policy decision not to prescribe 'how' planning authorities consult, i.e. not requiring a public meeting, but instead leaving it open for planning authorities to consult groups in the most appropriate way for them, taking account of existing local structures and engagement methods, and socio-cultural needs. The opportunity for a written consultation and written representations on the draft OSS may benefit those women who would not wish to attend mixed gender consultation meetings, but can input their comments from home. We are proposing a 12 week consultation period is proposed on draft open space strategies, it is hoped this is an appropriate length of time for those who may have less available free time to get involved in planning consultations outside other caring and parental responsibilities.
Sex/Gender:
Promoting good relations
Positive
Negative
None X
Reasons for your decision:
The draft Regulations are unlikely to impact on the promotion of good relations between men and women.
Do you think that the policy impacts on women because of pregnancy and maternity?
Pregnancy & Maternity:
Eliminating unlawful discrimination, harassment and victimisation
Positive X
Negative
None
Reasons for your decision:
The draft Regulations should, after consultation, be designed in such a way that they do not create unlawful discrimination related to pregnancy and maternity.
The draft OSS Regulations require that in discharging their duties to prepare an OSS planning authorities are to consider how the open space strategy will contribute to a series of outcomes including
- advancing equality and eliminating discrimination,
the policy aim behind this is to ensure good access to greenspace for all.
Pregnancy & Maternity:
Advancing equality of opportunity
Positive X
Negative
None
Reasons for your decision:
There is considerable evidence of beneficial effects of access to green space for pregnant women's health, including mental health. Green space in close proximity to the homes of pregnant women, and residential greenness were both positively associated with birth weight.
The draft OSS Regulations require that in discharging their duties to prepare an OSS planning authorities are to consider how the open space strategy will contribute to the outcome of 'improving health and wellbeing'.
Both sets of draft Regulations require planning authorities to provide information on 'Accessibility', this should help to ensure planning authorities consider how accessible open spaces and play opportunities are. Shared good practice and guidance will provide more detail in relation to accessibility, both in terms of the proximity of spaces to homes and their location within neighbourhoods.
The World Health Organisation has noted "The evidence shows that urban green space has health benefits, particularly for economically deprived communities, children, pregnant women and senior citizens. It is therefore essential that all populations have adequate access to green space, with particular priority placed on provision for disadvantaged communities.' The draft PSA Regulations require PSAs to include any Scottish Index of Multiple Deprivation data which the planning authority consider to be relevant.
Evidence from Public Health Scotland indicates pregnant women may find standing difficult and need facilities to sit down. Quality is an aspect that both sets of draft Regulations require planning authorities to consider and provide information on. Shared good practice and guidance will cover quality and could provide advice on the need to consider the need for seating for pregnant women.
The draft PSA Regulations propose that planning authorities must consult 'parents and carers', and 'the public' - this could include recent parents and parents who are pregnant, who may be able to advise on needs in relation to pregnancy and maternity.
The draft OSS Regulations also require planning authorities to consult with Public Health Scotland, who may also be able to advise on the needs of pregnant women and in relation to maternity.
We believe the overall ethos behind both sets of draft Regulations in terms of helping ensure there are enough, accessible, good quality open spaces and places to play should be reassuring for pregnant women to know their local planning authority will be considering these issues, so they will have places to take their children to in the future.
The consultation will seek views on whether the policy proposals are likely to have any disproportionate effects because of pregnancy and maternity.
Pregnancy & Maternity:
Promoting good relations
Positive
Negative
None X
Reasons for your decision:
The draft Regulations are unlikely to impact on the promotion of good relations pregnant women and other people.
Do you think that the policy impacts on people because of their sexual orientation?
Sexual Orientation:
Eliminating unlawful discrimination, harassment and victimisation
Positive X
Negative
None
Reasons for your decision:
The draft Regulations should, after consultation, be designed in such a way that they will not create unlawful discrimination related to sexual orientation.
The draft OSS Regulations require that in discharging their duties to prepare an OSS planning authorities are to consider how the open space strategy will contribute to a series of outcomes including
- advancing equality and eliminating discrimination,
the policy aim behind this is to ensure good access to greenspace for all.
Pregnancy & Maternity:
Advancing equality of opportunity
Positive
Negative
None X
Reasons for your decision:
Generally when it came to planning, as a whole, this group had no special needs or requirements - their views were representative of the general population.
In relation to access to play space and places to socialise, the evidence reveals LGBT children and young people may be significantly disadvantaged in accessing adequate play and leisure opportunities. Less than half LGBT children surveyed said there were enough places where they could safely socialise and be open about their sexual orientation. Evidence shows LGBTQ+ people 'switch' or hide their identities to feel safe in the majority of public spaces" .
In 2015, LGBO adults had lower mental wellbeing than the heterosexual group, when this is considered in conjunction with wider evidence on the widely recognised benefits greenspace can offer in terms of mental health, it underlines the importance that this group, can access quality greenspace and feel safe in doing so.
The evidence highlights the need for there to be enough safe places. The draft OSS Regulations require open space audits to include a statement on the quality of the open spaces and green networks in respect of each locality within their area, and for the totality of their area. Shared good practice and guidance will provide more detail on the types of considerations that contribute to quality - this is likely to link to the qualities of successful places set out in national planning policy, including being 'safe and pleasant'.
The Report on Queering Public Space, by University of Westminster, ARUP noted there was an urgent need today to rethink public spaces and create more inclusive, welcoming and hospitable environments for all members of our communities." Examples of spaces regarded as queer-inclusive were ones which had a diverse feel to them, respondents noted these were spaces softened by greenery or bodies of water, rather than harshened by hard surfaces. Space was not open and intimidating but broken up and intimate." Well designed and managed open spaces and green spaces have the potential to be intimate, safe green places. Shared good practice and guidance will provide more detail on quality, and design considerations.
The draft Regulations do not specifically require planning authorities to consult with people of different sexual orientations. However there are wider requirements to consult the public, and any other person or community body which the planning authority considers to be appropriate.
We will consider any views from representative organisations received through the consultation, on whether the policy proposals are likely to have any disproportionate effects in relation to sexual orientation.
Pregnancy & Maternity:
Promoting good relations
Positive
Negative
None X
Reasons for your decision:
The draft Regulations are unlikely to impact on the promotion of good relations between people of different sexual orientation.
Do you think that the policy impacts on transgender people?
Gender Reassignment:
Eliminating unlawful discrimination, harassment and victimisation
Positive X
Negative
None
Reasons for your decision:
The draft Regulations should, after consultation, be designed in such a way that they will not create unlawful discrimination related to gender reassignment.
The draft OSS Regulations require that in discharging their duties to prepare an OSS planning authorities are to consider how the open space strategy will contribute to a series of outcomes including
- advancing equality and eliminating discrimination,
the policy aim behind this is to ensure good access to greenspace for all.
Pregnancy & Maternity:
Advancing equality of opportunity
Positive
Negative
None X
Reasons for your decision:
Evidence shows LGBTQ+ people 'switch' or hide their identities to feel safe in the majority of public spaces", 54% of trans respondents avoided being open about their gender identity in 'the park' for fear of a negative reaction from others. Less than a third of transgender and non-binary people said there were enough places where they could socialise safely.
This highlights the need for there to be enough safe places. The draft OSS Regulations require open space audits to include a statement on the quality of the open spaces and green networks in respect of each locality within their area, and for the totality of their area. Shared good practice and guidance will provide more detail on the types of considerations that contribute to quality, and the likely link to the qualities of successful places set out in national planning policy, including being 'safe and pleasant'.
The Report on Queering Public Space, by University of Westminster, ARUP noted there was an urgent need today to rethink public spaces and create more inclusive, welcoming and hospitable environments for all members of our communities." Examples of spaces regarded as queer-inclusive were ones which had a diverse feel to them, respondents noted these were spaces softened by greenery or bodies of water, rather than harshened by hard surfaces. Space was not open and intimidating but broken up and intimate." Well designed and managed open spaces and green spaces have the potential to be intimate, safe green places, that transgender people can enjoy spending time in. Shared good practice and guidance will provide more detail on quality, and design considerations.
The draft OSS Regulations also require that in discharging their duties to prepare an OSS planning authorities are to consider how the open space strategy will contribute to the outcome of 'improving health and wellbeing'.
The draft Regulations do not specifically require planning authorities to consult with transgender people. However there are wider requirements to consult the public, and any other person or community body which the planning authority considers to be appropriate.
We will consider any views from representative organisations received through the consultation on whether the policy proposals are likely to have any disproportionate effects on transgender people.
Future shared good practice and guidance will highlight more detail on considerations around equality for everyone, including people with protected characteristics.
Pregnancy & Maternity:
Promoting good relations
Positive
Negative
None X
Reasons for your decision:
The draft Regulations are unlikely to impact on the promotion of good relations between transgender people and others.
Do you think that the policy impacts on people on the grounds of their race?
Race:
Eliminating unlawful discrimination, harassment and victimisation
Positive X
Negative
None
Reasons for your decision:
The draft Regulations should, after consultation, be designed in such a way that they will not create unlawful discrimination related to race. The draft OSS Regulations require that in discharging their duties to prepare an OSS planning authorities are to consider how the open space strategy will contribute to a series of outcomes including advancing equality and eliminating discrimination, the policy aim behind this is to ensure good access to greenspace for all.
Race:
Advancing equality of opportunity
Positive X
Negative
None
Reasons for your decision:
Evidence shows there is a health disparity created by BME people's lower presence in nature and open countryside. BME people are less likely to regularly visit natural settings. This low presence matters because BME people miss out on the pleasure and health benefits of natural spaces.
The draft OSS Regulations require that in discharging their duties to prepare an OSS planning authorities are to consider how the open space strategy will contribute to the outcome of 'improving health and wellbeing'. The draft OSS Regulations also require planning authorities to consult with Public Health Scotland, who may be able to advise on where there are particular issues of health inequalities and any racial element linked to that and access to open space in particular communities.
In terms of living within a five 5-minute walk of the nearest greenspace, there is a marked difference by ethnicity, with just 45% of ethnic minorities reporting living within a 5-minute walk, compared to 66% of those from the white ethnic group. The draft OSS Regulations include outcomes on 'advancing equality and eliminating discrimination' and 'improving access to green infrastructure, open space and green networks' - these are intended to work together to ensure good access for all groups.
Both sets of draft Regulations require planning authorities to provide information on 'Accessibility', at both a locality and whole local authority area, this should help to ensure planning authorities consider how accessible open spaces and play opportunities in their area are. Shared good practice and guidance will provide more detail about considerations in relation to accessibility, both in terms of the proximity of spaces to homes and their location within neighbourhoods.
Some people from specific communities of interest and identity described finding it difficult to get involved in decisions, or having no experience of involvement. For example, some asylum seekers, EU citizens, foreign language groups, and some people from different ethnic minority groups described experiences of being detached from the wider community and formal decision-making organisations and forums. In particular women from some minority ethnic groups may not wish to attend mixed gender consultation meetings. The draft Regulations do not specifically require planning authorities to consult with people of different races. However there are wider requirements to consult the public, and any other person or community body which the planning authority considers to be appropriate.
We have also taken the policy decision not to prescribe 'how' planning authorities consult, i.e. not requiring a public meeting, but instead leaving it open for planning authorities to consult groups in the most appropriate way for them, taking account of existing local structures and engagement methods, and socio-cultural needs. The opportunity for a written consultation and written representations on the draft OSS may benefit those women from minority ethnic groups who would not wish to attend mixed gender consultation meetings, but can input their comments from home.
The draft OSS Regulations require open space audits to include a statement on the quality, and accessibility of the open spaces and green networks in respect of each locality within their area, and for the totality of their area. Shared good practice and guidance will provide more detail on the types of considerations that contribute to quality, this is likely to link to the qualities of successful places set out in national planning policy, including being 'safe and pleasant'. Shared good practice and guidance will provide more detail on quality, and design considerations, it can also elaborate that when considering accessibility – inclusion is an important factor, including for people of different races and ethnic backgrounds.
The consultation will seek views from representative organisations on whether the policy proposals are likely to have any disproportionate effects in relation to race.
Race:
Promoting good relations
Positive
Negative
None X
Reasons for your decision:
The draft Regulations are unlikely to impact on the promotion of good relations between people of different races.
Do you think that the policy impacts on people because of their religion or belief?
Religion or Belief:
Eliminating unlawful discrimination, harassment and victimisation
Positive X
Negative
None
Reasons for your decision:
The draft Regulations should, after consultation, be designed in such a way that they will not create unlawful discrimination related to race.
The draft OSS Regulations require that in discharging their duties to prepare an OSS planning authorities are to consider how the open space strategy will contribute to a series of outcomes including advancing equality and eliminating discrimination. The policy aim behind this is to ensure good access to greenspace for all.
Religion or Belief:
Advancing equality of opportunity
Positive
Negative
None X
Reasons for your decision:
The data reveals that Christians or those having no religion were significantly more likely to live within 5 minutes of a greenspace compared to those belonging to another religion.
As well as the outcome around 'advancing equality and eliminating discrimination' the draft Regulations include the outcome of 'improving access to green infrastructure, open space and green networks' these are intended to work together to ensure good access for all groups.
Both sets of draft Regulations require planning authorities to provide information on 'Accessibility', at both a locality and whole local authority area, this should help to ensure planning authorities consider how accessible open spaces and play opportunities in their area are. Shared good practice and guidance will provide more detail on considerations in relation to accessibility, both in terms of the proximity of spaces to homes and their location within neighbourhoods.
There is evidence that women from minority ethnic groups may would not wish to attend mixed gender consultation, this may be linked to their religion or belief. We have also taken the policy decision not to prescribe 'how' planning authorities consult, i.e. not requiring a public meeting, but instead leaving it open for planning authorities to consult groups in the most appropriate way for them, taking account of existing local structures and engagement methods, and socio-cultural needs. The opportunity for a written consultation and written representations on the draft OSS Regulations may benefit those women from particular religions or beliefs who would not wish to attend mixed gender meetings, but can input their comments from home.
The draft OSS Regulations require open space audits to include a statement on the quality, and accessibility of the open spaces and green networks in respect of each locality within their area, and for the totality of their area. Shared good practice and guidance will provide more detail on the types of considerations that contribute to accessibility, this is likely to link to the qualities of successful places set out in national planning policy, including being 'safe and pleasant'. Shared good practice and guidance can also elaborate on aspects planning authorities should be aware of when considering accessibility – including considering whether there is appropriate provision for people of different religions or beliefs.
We will consider any views from representative organisations received through the consultation on whether the policy proposals are likely to have any disproportionate effects in relation to religion or belief.
Religion or Belief:
Promoting good relations
Positive
Negative
None X
Reasons for your decision:
The draft Regulations are unlikely to impact on the promotion of good relations between people of different religions or beliefs.
Do you think that the policy impacts on people living on low income or living in poverty?
Living On Low Income/ In Poverty:
Eliminating unlawful discrimination, harassment and victimisation
Positive X
Negative
None
Reasons for your decision:
The draft Regulations should, after consultation, be designed in such a way that they will not create unlawful discrimination related to poverty. The draft OSS Regulations require that in discharging their duties to prepare an OSS planning authorities are to consider how the open space strategy will contribute to a series of outcomes including 'advancing equality and eliminating discrimination'. The policy aim behind this is to ensure good access to greenspace for all.
Living On Low Income/ In Poverty:
Advancing equality of opportunity
Positive X
Negative
None
Reasons for your decision:
Evidence shows that health inequalities exist in Scotland, and that access to high quality green and open spaces, including space for play, can help prevent environmental factors causing health inequalities. As well as advancing equality, the draft OSS Regulations require that in discharging their duties to prepare an OSS planning authorities are to consider how the open space strategy will contribute to the outcome of 'improving health and wellbeing'. The draft OSS Regulations set out that in assessing current and future requirements, the planning authority is to have regard to how green infrastructure, open space and green networks are contributing to the outcomes and they must include a statement as to how their OSS contributes to the outcomes.
Access to outdoor space at home varies by tenure, homeowners are more likely to have gardens, 97% of homeowners have access to open private outdoor space. 19% of local authority tenants and 23% of private sector tenants do not have access to outdoor space at home. This highlights the need for sufficient public open space and play opportunities, particularly in the vicinity of those who may not be able to enjoy access to outdoor space at home.
People living in the most deprived areas are less likely to live within a 5 minute walk of their nearest greenspace than people in less deprived areas. Both sets of draft Regulations require planning authorities to provide information on 'Accessibility', this should help to ensure planning authorities consider how accessible open spaces and play opportunities are. Shared good practice and guidance will provide more detail on considerations in relation to accessibility, including in terms of the proximity to homes, and as part of 20 minute neighbourhoods.
Respondents living in the 15% most deprived areas of Scotland were more likely to agree or agree strongly that the quality of their local greenspace has reduced in the past 5 years (50% strongly agree/agree, compared to 40% of urban Scots). The draft OSS Regulations set out that open space audits may include information about the function of the open space and the extent to which it delivers those functions – this is seen as having a quality i.e. how well the space delivers on its functions and is fit for purpose. The draft OSS Regulations require open space audits to include a statement on the quality of the open spaces and green networks in respect of each locality within their area, and for the totality of their area. Shared good practice and guidance will provide more detail on the types of considerations that contribute to quality, this is likely to link to the qualities of successful places set out in national planning policy, including being 'safe and pleasant'.
A significant proportion, almost one in four of Scotland's children live in poverty, and the evidence shows this can impact on their opportunity to play, and how they play. Children living in the most deprived areas are also more than twice as likely to be obese than those living in the least deprived areas. In carrying out PSA, planning authorities may wish to refer to any Scottish Index of Multiple Deprivation data, which they consider to be relevant. This could help planning authorities identify areas and prioritise action where the provision of local play opportunities could help mitigate the impact of child poverty, and disparity of provision and unequal access.
The evidence indicates that internet access and confidence using it varies by tenure and household income. The draft OSS Regulations contain a provision requiring planning authorities to publicise the consultation on their draft OSS using adverts in the local press, to help ensure those who don't have the internet have the opportunity to offer their views on the draft open space strategy.
We will consider any views from representative organisations received through the consultation on whether the policy proposals are likely to have any disproportionate effects in relation to people living on low incomes and/or in poverty.
Living On Low Income/ In Poverty:
Promoting good relations
Positive
Negative
None X
Reasons for your decision:
The draft Regulations are unlikely to impact on the promotion of good relations between people living on low income and others on higher incomes.
Stage 4: Decision making and monitoring (Identifying and establishing any required mitigation action)
Have positive or negative impacts been identified for any of the equality groups?
This interim review has identified at this stage a range of potentially positive impacts of the draft Regulations.
As this is a preliminary and indicative assessment of all the potential impacts at this interim stage of the EQIA, it will be subject to further review and revision after the consultation has taken place and in finalising the Regulations.
Shared good practice and guidance will provide more details on equality issues to be considered when auditing open spaces, and assessing play sufficiency, and in engaging people on those; as well as in developing the open space strategies and its policies and proposals.
Is the policy directly or indirectly discriminatory under the Equality Act 2010[133]?
No.
There is no evidence, so far within this interim EQIA that the policy is directly or indirectly discriminatory under the Equality Act 2010.
If the policy is indirectly discriminatory, how is it justified under the relevant legislation?
N/A
If not justified, what mitigating action will be undertaken?
N/A
Describing how this Interim Equality Impact analysis has shaped the policy making process so far
Throughout discussions with the OSSPSA Working Group and with planning authorities we highlighted the need to consider equalities for people of different protected characteristics, as a core part of the policy making process.
In developing the draft Regulations, our approach has been significantly influenced by the evidence on equalities. Taking account of the issues raised, in relation to the lived experience of people from different protected groups/characteristics, relevant aspects will be addressed either within the draft Regulations or will be expanded upon through shared good practice and guidance.
Aspects in the draft Regulations:
- advancing equality and eliminating discrimination outcome – members of the Working Group suggested the OSS Regulations should require planning authorities to take an outcomes based approach when preparing their open space strategy. Given existing inequalities in access to open space, improving equality was identified as a proposed outcome. The proposed wording was refined to 'advancing equality and eliminating discrimination' following examination of responses from Engender to other EQIAs.
- consultees lists – across the two sets of draft Regulations there are requirements for planning authorities to consult; children and young people, disabled people, parents and carers, older people, the public, community councils and any other person or community body which the planning authority considers to be appropriate.
- consultation – there was an option to prescribe in the draft OSS Regulations the means how planning authorities would have to consult. But taking account of the evidence that some women from ethnic minority or different religious beliefs may not feel comfortable attending mixed gender consultation meetings, the policy decision was taken not to prescribe 'how' planning authorities consult, for instance not requiring a public meeting. Instead there is flexibility for planning authorities to consult groups in the most appropriate way for them, taking account of existing local structures and engagement methods, and socio-cultural needs.
- quantity, quality and accessibility information requirements – evidence shows different groups experience different levels of quantity, quality and accessibility to open space and play spaces. Both sets of draft Regulations require planning authorities to consider the 'quantity', 'quality' and 'accessibility' of open space, and play opportunities, respectively, on a locality basis, this will help inform local authorities on the amount, and quality of open space and places to play within local neighbourhoods, to seek to ensure greater equity.
- press advert requirements – this provision was added to the draft OSS Regulations to ensure older people (who may not have access to the internet) are aware of, and so not excluded from the consultation on the draft OSS for their area.
Aspects to address through shared good practice and guidance:
- information on age groups of children by sex – to help ensure planning authorities consider the play needs of boys and girls of all ages.
- other demographic information – to help ensure planning authorities advance equality and eliminate discrimination
- consultation – to expand on the importance of engaging a wide range of people in particular those with protected characteristics.
- deprived communities – we encourage planning authorities to refer to the Scottish Index of Multiple Deprivation (SIMD) or similar data which they consider to be relevant. This should help them identify areas where they may be fewer children with access to their own garden, and where the need for play opportunities outside the home may be greater, and offer significant health and wellbeing benefits.
- accessibility – to provide more detail on the types of considerations that contribute to accessibility, linked to the qualities of successful places set out in national planning policy, including being 'safe and pleasant'; and in relation to different protected characteristics including people with disabilities, gender, age, and religion or belief.
- quality and safety – to provide more detail on the types of considerations that contribute to quality, linked to the qualities of successful places set out in national planning policy, including being 'safe and pleasant' - qualities which the evidence shows is particularly important to women and girls, children and older people, as well as non-binary people.
- child friendly versions – to help ensure equality of opportunity for younger age groups in terms of engagement, we encourage planning authorities to consider publishing a child-friendly version alongside the main documents (PSA and OSS respectively).
The interim equality impact analysis has helped highlight areas where there is less evidence on people with protected characteristics and the other characteristics included within this interim EQIA. It helped shape our plans for engagement during the consultation.
We intend to carry out a targeted consultation with children and young people to ensure that there are no unintended consequences from the draft Regulations. We have been working closely with Play Scotland and A Place In Childhood to develop an engagement strategy to seek the views of children and young people from across Scotland. During the public consultation period we intend to carry out targeted engagement, with a tailored questionnaire to children and young people from different age groups, backgrounds and parts of the country (urban / rural / island and more deprived / less deprived communities), including with groups for children and young people with additional support needs, and those from a BAME background, refugees / asylum seekers, LGBTQ, and young carers.
Within the consultation itself, we have highlighted a number of areas where there are potential impacts on different groups to allow consultees to consider these in commenting on the draft provisions.
Monitoring and Review
Evidence available and gathered during the consultation will help inform the full and final Equality Impact Assessment which will be completed at the end of the consultation period.
The consultation responses will be fully analysed and will inform the drafting of the final Regulations to be laid in Parliament, as well as the full and final EQIA, and any future guidance supporting the Regulations.
Any subsequent feedback will also be considered and the any future guidance may be updated.
Monitoring levels of access to green and blue space can be carried out over time comparing any changes from the baseline (2019) data as recorded for the national indicator, which includes breakdowns by age, disability, ethnicity, gender, religion, SIMD and urban rural classification.
Stage 5: Authorisation of EQIA
Declaration
I am satisfied with the interim Equality Impact Assessment that has been undertaken for the consultation on secondary legislation on Open Space Strategies and Play Sufficiency Assessments and give my authorisation for the results of this interim assessment to be published on the Scottish Government's website.
Name: Fiona Simpson
Position: Chief Planner
Contact
Email: OSSPSAconsultation@gov.scot
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