Open Space Strategies and Play Sufficiency Assessments Regulations: impact assessments

Appendix B: Children's Rights and Welfare Impact Assessment (CRWIA)

Stage 3 - Publication

Date of publication: December 2021

CRWIA title: Secondary Legislation Open Space Strategies and Play Sufficiency Assessments

Executive summary

This impact assessment relates to the proposals for the introduction of secondary legislation to support the new duties on planning authorities to prepare Open Space Strategies (OSS) and Play Sufficiency Assessments (PSA).

This impact assessment considers how the proposals relate to the relevant Articles of the UNCRC, in particular relating to Articles 31, 15 and 12; as well as having some relevance to Articles 3, 23 and 24.

It considers

• any impacts the proposals may have on children in general and / or on any specific group or groups of children;
• how the proposal may contribute to the wellbeing of children and young people based on the Getting it Right for Every Child's SHANARRI indicators;
• if the proposals better or further effect the implementation of the UNCRC in Scotland; and
• the evidence base used to inform the assessment.

Background

The right to rest and leisure, to engage in play and recreational activities appropriate to the age of the child is enshrined under Article 31 of the UNCRC. Research also shows that play builds health and wellbeing in children and is essential to healthy development from birth to adulthood, contributing to the capacity for learning, resilience and the development of physical, cognitive, social and emotional skills. Open spaces provide many opportunities for children to play and for relaxation and recreation. However, various research and surveys including the 2016 Scottish Households Survey, showed that whilst most children had access to play areas in their neighbourhood, the availability differed according to levels of deprivation within urban areas. It also noted the quality and accessibility of the play spaces for children, including children with a disability and/or from particular social, cultural or economic background were variable.

The Planning (Scotland) Act 2019 made it a statutory requirement for planning authorities to assess the sufficiency of play opportunities in their area for children in preparing the Evidence Report for their Local Development Plan.

Planning policy has promoted the preparation of an open space audit and strategy and, whilst this has not been a mandatory requirement, most authorities have a form of OSS that they use to inform their local development plans and planning decisions. The Planning (Scotland) Act 2019 made it a statutory requirement for planning authorities to prepare an OSS.

Scope of the CRWIA, identifying the children and young people affected by the policy, and summarising the evidence base

Scope - All children are potentially affected by the proposals as both sets of draft Regulations require planning authorities to consult children in carrying out their duties; this is to ensure children are involved and due consideration is taken of their views to inform the preparation of the OSS and PSA.

Evidence - Various surveys and research data highlight a number of issues, including those of access, use, quality, inclusion etc. relating to children's use of open spaces and play spaces and that some disparities exist for children with disabilities and from different socio-economic backgrounds.

Children and young people's views and experiences

Benefitting from greenspace

• Research shows the positive impacts of quality greenspace for children includes the ability to cope with life stresses, concentration, activity levels and social skills.

Accessing the outdoors, greenspace, open space, play space

• 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 the most deprived urban areas said they had less access to a natural environment or wooded area in their neighbourhood, compared to other urban areas. Children in rural areas have more access to fields, natural environments and woods, whereas those in urban areas have more access to parks.

Table 13.1: Types of children play area available in the neighbourhood by Urban Rural Classification and Scottish Index of Multiple Deprivation (SIMD), Percentages, 2016 data

Housholds	Urban			Rural	Scotland
	20% most Deprived	Rest of Urban	All Urban
Playground	52	59	57	52	56
Park	64	68	67	55	65
Football or other games pitch	42	48	46	43	46
Field or other open space	46	54	51	62	53
School Playground	35	45	42	39	42
Natural environment / wooded	36	50	46	72	50
Access to at least one play area	91	92	91	94	92
Access to none	9	8	8	6	8
Base (minimum)	280	800	1,080	290	1,370

Columns may add to more than 100 per cent since multiple responses were allowed.

• The 2016 Scottish Household Survey also 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%).
• The Report by the Scottish Alliance for Children's Rights on the State of Children's Rights in Scotland, states children have said that parental worries about traffic can mean they are not allowed to play in the street. Parking is also a problem, with cars parked on the pavements or blocking places where children could play or cross the road.
• 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; and that the restriction on parks and limited opportunities to access the outdoors had affected their health and wellbeing.

Quality of greenspace and play areas

• The Report by the Scottish Alliance for Children's Rights on the State of Children's Rights in Scotland, highlights that children have said they are disgusted by dog mess on pavements and in parks and playgrounds and that this stops them from playing in spaces that are supposed to be for them.
• The Greenspace Use and Attitudes Survey 2017 reveals 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%. This could affect the quality of spaces available to children living in the most deprived areas and their experience of using local greenspaces.

Feeling safe

• Recent 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 litters particularly where there's evidence of items used for taking drugs having been left.
• Girls in Scotland 2018 indicates 18% of girls felt unsafe going to the park by themselves. 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.
• The 2016 Scottish Household Survey also highlighted that over 50% of households in the 20% most deprived urban areas are very or fairly concerned of children being harmed by adults in playgrounds or parks compared to around 32-35% in the rest of urban areas. The 2016 Scottish Household Survey also noted 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.
• The 2016 Scottish Household Survey showed, the average age it is felt safe for children to play without adult supervision is 10 (for parks, playgrounds, football or games pitches, fields or other open spaces and school playgrounds, with them generally having to be 11 to play in natural environments / wooded areas by themselves, and it being seen safe for them to play in the street a year younger at 9. In rural areas, across the different types of spaces it was felt safer for children to play out without supervision a year younger than the position for the rest of Scotland.
• Together's members have reported that bullying in public places is a significant barrier in accessing play for children with learning disabilities.

Spending free time

• Girls in Scotland (2020) reports 'most girls in Scotland lead an active lifestyle.
• 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 young, that children may spend more time on other activities rather than playing outside.
• Research on The Health Impacts of Screen Time 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.

Connection to place / neighbourhood

• Democracy Matters for Children 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', 'more trees', 'protected wildlife', '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.
• The 2018 Scottish Household Survey found that just over seven in ten (73 per cent) of those aged between 16 and 24 said they felt a very or fairly strong sense of belonging to their community, compared to almost nine in ten adults (87 per cent) aged 75 and above.

Experiences of children with a disability

• 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.
• 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.

Experiencing gender issues in greenspaces and play areas

• Girls in Scotland (2020) reports 'when it comes to sport and play, girls in Scotland feel constrained by gender stereotypes from a very young age'.
• Make Space for Girls' research, 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.

Getting involved in planning / decision making /use of digital

• 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.'
• A survey undertaken by Young Scot (2017) to accompany Places, People and Planning concluded 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; and
  • the majority of young people feel that their local council should have to prove that they have involved children and young people in their plans.
• Democracy matters to Children (2020) noted that 'children's paths to meaningful involvement in decision-making are currently limited and many children have limited or no experience of participation in democratic processes'. A number of local issues were identified as ones which children wanted to have a say in – this included planning and the built environment.
• In May 2020, the Scottish Government published Young people's participation in decision making: attitudes and perceptions It noted that around six in ten young people surveyed agreed that adults were good at listening to their views (57 per cent). This was similar to findings in 2017. 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.
  • Boys were more positive on both questions.
  • Older children, for example pupils in S6, were more negative.
  • Respondents with a mental or physical health condition were less positive.
• Hard to Reach, Easy to Ignore (2017) noted that language barriers lack of confidence and dominant characters can discriminate against some people during community engagement, specifically including young people.
• Digital - Ofcom reported (February 2020) noted that social media is central for both tweens and teens. Some 21% of 8-11s and 71% of 12-15s have a social media profile. It also noted that 2019 saw an increase in the proportion of 12-15s who use social media to support causes and organisations by sharing or commenting on posts (18% in 2019 vs. 12% in 2018). In addition, one in ten have signed petitions on social media in the last year.

Key Findings, including an assessment of the impact on children's rights, and how the measure will contribute to children's wellbeing

Relevant UNCRC Articles and the potential impacts the proposals may have on children's rights:

Article 3 (best interest of the child) every decision and action taken relating to a child must be in their best interests.

One of the key principles behind the proposed provisions in the draft Regulations is to support the interests of the children and young people in spatial planning and to ensure that their needs and how they use open spaces and play spaces are recognised and considered, amongst the needs of the wider community.

Article 31 (leisure, play and culture) which relates to every child having the right to relax and play.

In requiring planning authorities to assess the sufficiency of outdoors play opportunities and to take cognisance of children's improved access into open spaces, both sets of draft Regulations will help ensuring better and adequate provisions and access to outdoor spaces for play and relax, thus contributing to children's health and wellbeing.

Article 15 (freedom of association) 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.

The potential impacts and contributions are similar to those assessed under Article 31 above.

Article 12 (respect for views of the child) every child has a right to express their views and have them given due weight in accordance with their age and maturity. Children should be provided with the opportunity to be heard, either directly or through a representative or appropriate body. This links to the Respected and Responsible SHANARRI wellbeing indicators.

In requiring planning authorities to engage children and young people and to consult them during the processes of preparing OSSs and PSAs, both the draft OSS Regulations and the draft PSA Regulations ensure the involvement of children and young people and that they can participate in the matters affecting them and their views will be taken account of.

Article 23 (children with a disability) a child with a disability has the right to live a full and decent life with dignity and, as far as possible, independence and to play an active part in the community. Governments must do all they can to support disabled children and their families.

The draft PSA Regulations require planning authorities to consult with children, as well as with parents and carers during the process. This is intended to ensure all children and those with their best interests at heart are consulted during the preparation of the PSA. The draft OSS Regulations, being wider in scope, include a more general requirement on consulting people with disabilities.

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.

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, including for children with a disability. Shared good practice and guidance may provide more details on what should be considered in relation to accessibility, such as issues around:

• getting there - proximity of spaces to homes and their location within neighbourhoods, safe routes;
• design considerations within the spaces, in terms of the path network and finishing materials etc;
• the inclusion of the facilities and equipment provided; and
• feeling safe and welcome (accessible to people from different protected groups).

Article 24 (health and health services) every child has the right to the best possible health. Governments must provide good quality health care, clean water, nutritious food, and a clean environment and education on health and well-being so that children can stay healthy.

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.

Recognising improved access to open spaces and play spaces will ensure better opportunities for children to be active and to play outdoors and contribute to many positive health impacts on children and young people, as well as ensuring their development, contributing to the capacity for learning, resilience and the development of physical, cognitive, social and emotional skills.

SHANARRI wellbeing indicators

The draft Regulations will support public bodies in Scotland in meeting their duties to safeguard, support and promote the wellbeing of children in their area, with wellbeing defined by eight wellbeing indicators. The SHANARRI indicators are: Safe, Healthy, Active, Nurtured, Achieving, Respected, Responsible, and Included.

Safe – Shared good practice and guidance may expand on considerations when carrying out audits of open spaces and assessments of play opportunities. This could include considerations around whether spaces and play equipment is fit for purpose, well maintained and safe; whether the location and design of the space allows natural surveillance, with good lighting etc, whether access to the play space is safe, with minimised traffic risks and appropriate crossing provision.

Healthy – Exposure to green space during pregnancy is associated with foetal growth and good birth weight outcomes and a number of child cognitive development indicators.^[134]

Research shows that accessing green space as a child leads to improved health outcomes in older age. Forestry Commission research^[135] also found that "Residents in 'high greenery' environments were 3.3 times more likely to take frequent physical exercise than those in the lowest greenery category."

Literature from WHO^[136] and other sources have found that there are a number of positive health benefits associated with urban greenspace or greener environments. These benefits include improved mental health and wellbeing, cognitive function, reduction in all-cause mortality, reduced cardiovascular morbidity and mortality, reduced prevalence of type 2 diabetes, enhanced quality of life and improved pregnancy outcomes. The benefits of high quality greenspace on physical and mental health appear to be most significant for certain groups within the population, including children.^[137]

Play builds health and wellbeing in children. Professor Sir Harry Burns, Former Chief Medical Officer in Scotland said "Investing in children's play is one of the most important things we can do to improve children's health and wellbeing in Scotland".^[138]

The benefits of green and open space to people's mental health and wellbeing became very evident during the Covid-19 pandemic. In 2020, almost three-quarters (70%) of people surveyed felt spending time outdoors in nature helped them to de-stress, relax and unwind and 56% agreed that it improved their physical health.^[139]

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:

• improving health and well-being;
• improving access to green infrastructure, open space, and green networks; and
• advancing equality and eliminating discrimination.

Active – For children and young people, physical activity includes play, games, sport, practicing fundamental movement skills, recreation and taking part in planned exercise. Requiring councils to assess the sufficiency of play opportunities for children, should support the understanding of whether there is adequate provision locally for children to live an active life. The draft OSS Regulations require planning authorities to identify the 'type' of each open space (over the 0.2ha threshold) which should help to show the level of provision of sports areas, play areas as well as general amenity greenspace, where children can be active.

Nurtured – Children's play is spontaneous, happens in a variety of ways, and children play in different spaces and places when they are outdoors. The different ways of play can be physical involving running, jumping, balancing etc; or can be creative involving making things, building dens, chalking and drawing; or can be social involving hanging around with a few friends, being quiet and relaxing. These different ways of play are crucial for children's growth and development, in improving learning and developing skills that prepare them for adulthood. Research^[140] shows play is essential to healthy development from birth to adulthood, contributing to resilience and the development of physical, cognitive, social and emotional skills.

The draft PSA Regulations set out two different categories of play spaces, not limiting to those play areas specifically designed for play. By requiring planning authorities to also consider wider play opportunities in open spaces, it can support them to consider the broader environment and maximise the opportunities for children to play outdoors in their neighbourhoods.

Achieving – Play contributes to children's capacity for learning. Learning Through Landscapes research^[141] notes that outdoor learning not only helps children and young people understand their own interests, but it also helps them to increase their knowledge and academic skills. In their research study, 20% of outdoor learning took place in greenspace, beyond playgrounds in school grounds. There is scope for planning authorities to consider through policies and proposals in their open space strategy opportunities to provide or enhance greenspace, particularly those near schools and nurseries that could be utilised to a greater extent for outdoor learning and increasing attainment.

Natural spaces in and around the school environment are also associated with cognitive development in children; one study found that high levels of exposure to green spaces was associated with a 5% improvement in working memory, 6% increase in superior working memory, and a 1% reduction in inattentiveness.^[142]

Play Scotland also note there is considerable evidence^[143] that playing helps support children's cognitive development. This includes the development of language skills, problem solving, gaining perspective, representational skills, memory and creativity. Playing in outdoor environments with natural features can also improve children's concentration, self-confidence, self-regulation and an awareness of the needs of others. The new regulations to support the preparation of PSAs across Scotland should help ensure there are sufficient places for children to play which in turn can support their development, learning and other achievements.

Respected, Responsible, Included – The draft Regulations include specific requirements to consult with children and young people. The draft PSA Regulations require the planning authorities to engage children during the process of preparing PSA. Shared good practice and guidance may provide more details on the potential for co-production on aspects of the PSA. We encourage planning authorities to consider publishing a suitable child friendly version of the assessment report that is more accessible for children.

This will support planning authorities in ensuring they meet their duties to safeguard, support and promote the wellbeing of children in their area. In particular relating to the indicators Respected, Responsible, and Included, by ensuring children are involved in the process, and their views are respected and given due regard as part of the process

Monitoring and review

In terms of monitoring the Planning (Scotland) Act 2019 requires planning authorities to undertake the Play Sufficiency Assessment in preparing the Evidence Report for their Local Development Plan (LDP). The Evidence Report will be assessed on whether it contains sufficient information to enable the planning authority to prepare a proposed plan. Where it is determined that this is not the case, which may include a PSA not being provided, this could prevent the planning authority from moving forward to the next stage in preparing its LDP. LDPs are subject to a 10 year review cycle.

The draft OSS Regulations require an updated open space strategy to be published within the period of 10 years beginning on the date of publication of the most recent open space strategy. This is intended to link to the review cycle for LDPs, and support evidence led plan making.

Bill - Clause	Aims of measure	Likely to impact on	Compliance with UNCRC requirements	Contribution to local duties to safeguard, support and promote child wellbeing
Draft Open Space Strategies Regulations:
Reg (2) Amendment of section 3G(4) of the Town and Country Planning (Scotland) Act 1997 (Definitions)	Greater clarity of understanding of key terms ('open space', 'green network', 'green infrastructure' and 'ecosystem services' and 'green spaces'), as consulted on with stakeholders.	-	N/A	N/A
Reg (3) Preparation of open space strategy	To introduce an outcomes based approach - improved focus on how the OSS can contribute to a range of aspects to support the wider health and wellbeing of the area including social benefits to the place and environment. Requires planning authorities to identify any strategic green networks in their wholly or partially in their area, and how green networks may be enhanced	Articles 31,15,23,24	The draft Regulations require that planning authorities must take into consideration how the policies and proposals in the strategy contribute to a series of outcomes, including: improving access to green infrastructure, open space and green networks, supports Article 31 so children have access to spaces to relax and play, and Article 15 to meet with other children improving health and wellbeing, links to Article 24 (health and health services) - every child has the right to the best possible health. advancing equality and eliminating discrimination, links to Article 23 (children with a disability).	One of the suggested outcomes specifically covers wellbeing.
Reg (4) Audit of existing open space provision	To set out the types of open spaces to be included in the audit. To highlight factors that may be included in audits, including environmental considerations eg. accessibility, the function of the space, the extent to which open space delivers on its functions, the presence of play opportunities and condition. To require planning authorities to include statements on accessibility, quality and quantity of open spaces and green networks in each locality and for the totality of the area. To set out consultees who the planning authority is to seek the views of in carrying out the audit, including children and young people, people with disabilities, the public, any other person or community body which the planning authority considers to be appropriate and key agencies (including Public Health Scotland).	Articles 31,15,23,24	Auditing open spaces in this way can help in considering whether there are enough, good quality, accessible open spaces. This supports children under Article 31 in having spaces to relax and play, and under Article 15 having spaces where to meet with other children in their local community (locality) Linking back to the outcomes approach also ensures in auditing open spaces planning authorities are considering how well they improve access to open spaces and green networks, and advance equality and eliminate discrimination - this would include for children with a disability (Article 23) In relation to Article 24 there is the requirement to consult with Public Health Scotland and the link to the outcome on improving health and wellbeing.	One of the suggested outcomes specifically covers wellbeing.
Reg (5) Assessment of current and future requirements	Requires the planning authority to consult in carrying out the assessment of current and future requirements (including with children and young people, the public, community councils, and key agencies (including Public Health Scotland). Ensuring engagement is at a meaningful 'neighbourhood' / locality level to help identify requirements for open space to help support delivery and action at a local level.	Articles 31,15,23,24	Helping to ensure the current and future needs of children in relation to open space are met which can support Article 31 in having spaces to relax and play, and Article 15 to meet with other children including in their local community (locality). By linking back to the outcomes approach also ensures when planning authorities are considering open space requirements they are considering advancing equality including for children with a disability (Article 23) and improving health and wellbeing (Article 24).	One of the suggested outcomes specifically covers wellbeing.
Reg (6) Consultation on draft open space strategy	Improved opportunities for engagement, with a draft OSS being published and consulted upon for a period of 12 weeks (with a requirement for notice in local newspapers), prescribed groups to be consulted, including children and young people, the draft proposals also require consultation with key agencies, e.g. NatureScot, SEPA, Historic Environment Scotland, to ensure environmental issues are considered; on the social side there is also requirements to consult Public Health Scotland. The draft Regulations also require planning authorities to have regard to any valid representations received from anyone consulted under the Regulations.	Articles 12 and 23	(Article 12) Respect for the views of the child - Children should be provided with the opportunity to be heard, either directly or through a representative or appropriate body; (Article 23) - Children with disabilities Governments must recognise the right of the disabled child to special care, and ensure the disabled child has effective access to recreational opportunities.	Requires planning authorities to consult children and young people, and people with disabilities, in the preparation of the OSSs and to have regard to any valid representations.
Reg (7) Publication of open space strategy	Allows the planning authority to modify the draft OSS to take account of timely made representations, any matters arising in consultation and any minor drafting or technical matters. Provides for transparency and accountability – requirements for electronic publication.	Article 3	Article 3 (Best interest of the child) - In considering whether to modify the OSS to take account of representations, the planning authority should be considering Article 3 decisions in a child's best interests.	Requires planning authorities to publish the final OSS electronically – allowing children and those with their best interests at heart to have access to the OSS for their area.
Reg (8) Review of open space strategy	Ensures the OSS is reviewed and an updated OSS published within 10 years of the most recent OSS.	Articles 31,15,12,23,24	By ensuring the OSS is updated, it will help ensure planning authorities have relevant information on which to plan for open space and green networks, providing opportunities for different generations of children to be involved and express their views.	One of the proposed outcomes for planning authorities to take into consideration when preparing their OSS specifically covers wellbeing.
Draft Play Sufficiency Assessments Regulations
Form and content of PSA Regs 3(1) and 3(2) - PSA to be in the form of a report, incorporating map-based information to identify and locate play spaces Reg 3(3) PSA must describe the play opportunities for all ages of children Reg 3(4) PSA must include statements as regards quality, quantity and accessibility in respect of each locality within the planning authority's area Reg 3(5) PSA must include statements as regards quality, quantity and accessibility in respect of the totality of the planning authority's area	Ensure availability of good quality information and data on overall play opportunities for children, assessment of the quality, quantity and accessibility of the play opportunities locally and the accessibility of such information through a completed report containing written statements and associated map-based information.	Articles 31(and its general comment No. 17 (2013), 15, 23, 24	Article 31 and its general comment No. 17(a) – "Government must strengthen its efforts to guarantee the right of the child to rest and leisure and to engage in play and recreational activities appropriate to the age of the child, including by adopting and implementing play and leisure policies with sufficient and sustainable resources"; Article 15 Freedom of association – ensures that there are spaces to meet with other children including in their local community (locality); Article 23 Children with disabilities - Governments must recognise the right of the disabled child to special care, and ensure the disabled child has effective access to recreational opportunities; Article 24 Health and health services; Best interests of the child - Governments must take all appropriate legislative and administrative measures to ensure that children have the protection and care necessary for their wellbeing	Requires planning authorities to identify, assess and report on the sufficiency of outdoors play opportunities for children of all ages, and enable children in exercising their right to rest and leisure, to engage in play and recreation activities; as well as their right to freedom of assembly; to meet with other children. Shared good practice and guidance may help expand on considerations to be given to children with disability and other protected characteristics to ensure inclusion.
Reg (4) Consultation	Advancing equalities, ensuring opportunities to participate and influence.	Articles 12, 23 and Article 31(and its general comment No. 17 (2013)	Article 12 Respect for the views of the child - Children should be provided with the opportunity to be heard, either directly or through a representative or appropriate body; Article 31's general comment No. 17(c) – "Fully involve children in planning, designing and monitoring the implementation of play policies and activities relevant to play and leisure, at the community, local and national levels". Article 23 Children with disabilities – "Governments must recognise the right of the disabled child to special care, and ensure the disabled child has effective access to recreational opportunities".	Requires planning authorities to consult children, and their parents and carers who have their best interests at heart, during the preparation of the PSA thus ensuring children can participate meaningfully, their views are respected and taken account of. Shared good practice and guidance may offer advice to help advance engagement with children with disability and other protected characteristics to ensure inclusion.
Reg (5) Publication	Provides information, ensuring accessibility, transparency and accountability.	Article 12	Respect for the views of the child - Children should be provided with the opportunity to be heard, either directly or through a representative or appropriate body.	Requires planning authorities to publish the final PSA electronically ensuring children and those with their best interests at heart to have access to the PSA for their area. We encourage planning authorities to publish a child friendly version to ensure children can readily understand.

CRWIA Declaration

Authorisation

Policy lead:

Kristen Anderson (Open Space Strategies)

Kuan Loh (Play Sufficiency Assessments)

Date:

08/12/2021

Deputy Director or equivalent:

Dr Fiona Simpson, Chief Planner

Date:

08/12/2021