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

The public consultation on draft Open Space Strategies regulations and draft play sufficiency assessment regulations ran between 17 December 2021 to 31 March 2022. This report presents the analysis of the consultation responses received by the Scottish Government from stakeholders.

Executive Summary


The joint consultation on the draft Open Space Strategies (OSS) regulations and Play Sufficiency Assessments (PSA) regulations forms part of the Scottish Government's wider programme of work implementing the Planning (Scotland) Act 2019. The Act introduced new duties on planning authorities to prepare and publish Open Space Strategies and to assess the sufficiency of play opportunities in their area for children.

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

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

In addition to the public consultation, a Children and Young People's (CYP) survey was designed and coordinated by Play Scotland. Slightly different versions were used for primary and secondary school-aged respondents. This element of the consultation sought to gather the views of children and young people on issues relevant to the subject of the consultation.


Horizons Research was appointed to carry out an analysis of the data collected during the public consultation and in response to the CYP survey.

The process for analysis included:

  • Cleaning and validating the data set - this involved collating all the data gathered, identifying any issues or anomalies, and categorising respondents.
  • Quantitative analysis - involving the development of formulae for closed questions in the consultation and survey, and the presentation of number-based analysis in tables as appropriate.
  • Qualitative analysis - involving the review of all comments made to each question, identification of themes, and describing the weight of support and patterns amongst respondents where this was possible.

Respondent Profile

A total of 68 responses were provided to the main consultation. The largest respondent group was local or planning authorities, which accounted for 42.6% of responses.

A further 1,066 young people were involved in the CYP survey - either by submitting an individual response (140) or participating in a group response (926).

Summary of respondent views on the draft Open Space Strategies Regulations

  • The vast majority of respondents (89%) supported the outcomes-based approach proposed by the Scottish Government, with a similar proportion (87%) agreeing with the specific outcomes proposed in the draft open space regulations.
  • The majority of respondents supported the specific definitions used in the draft Regulations for "open space" (63%), "green space" (64%), "greenspace infrastructure" (78%) and "green networks" (71% agreement). Respondents asked for further clarity in the regulations or for guidance, especially in relation to blue and grey spaces, spaces which may be excluded, and the relationships between different terms and across policies.
  • There was overall support (77%) for the proposed thresholds for open space audits. These were seen as workable, sufficiently flexible and in keeping with wider policy practice. However, challenges for rural authorities were mentioned.
  • The majority of respondents (79%) agreed with the information that would be required to be included in audits, although some felt further guidance might be needed. A further 82% agreed with the proposed additional information that planning authorities 'may' include, according to the draft regulations.
  • There was support (83% agreement) for requirements to require locality level place-based information in open space audits.
  • The majority of respondents (82%) agreed with the proposed high-level aspects that should be considered in statements. Although clarity was sought on "accessibility" and "quality" in particular.
  • The proposed list of consultees for open space audits was widely supported (87%), although respondents emphasised the need to be inclusive in any consultation activity.
  • The vast majority of respondents (89%) agreed that assessments of current and future requirements should have regard for open spaces and green networks, and how these contribute to the outcomes. A similar proportion (88%) agreed that the assessment should be informed by engagement with specific groups set out in the regulations.
  • There was broad support for requiring Open Space Strategies to: include a statement on outcomes (90% agreement), identify strategic green networks (89%), and identify how green networks should be enhanced (84%).
  • The draft regulations set out proposed consultation requirements on draft Open Space Strategies, which 77% of respondents agreed with. Further, 75% agreed with proposed publication requirements.
  • A 10-year minimum review period for open space strategies was supported by the majority of respondents (82%).

Summary of respondent views on the draft Play Sufficiency Assessments Regulations

  • The majority of respondents supported the definitions of "children" (87% agreed), "localities" (85%), and "open space" (75%). Comments reflected the same themes raised in relation to definitions for the draft regulations for Open Space Strategies. Further, a majority (78%) agreed with the definition of "play spaces".
  • There was broad support for the required approach to mapping play spaces, with 80% of respondents agreeing with the proposed regulations. However, clarity was sought around how best to include areas of open space not specifically for play.
  • The vast majority of respondents (89%) supported the requirement to assess play opportunities by age, although respondents did highlight the drawbacks of too narrow an approach, and the importance of meeting the needs of older young people.
  • When asked for their views on the aspects to be considered in assessments, 88% agreed with the inclusion of "accessibility", "quantity", and "quality". However, there was discussion about whether "accessibility" should or could mean "inclusivity". In addition, the vast majority of respondents (85%) agreed planning authorities should provide written statements on play sufficiency for the totality of the area and for each locality.
  • The vast majority of respondents agreed with the proposed consultation requirements for play sufficiency assessments (93%) and the proposed list of consultees (87%). Similarly, 90% agreed with the publication requirements.

Cross-cutting issues

A number of issues were consistently identified across questions and various areas of the main consultation:

  • Some respondents highlighted their support for engagement work to be accessible and inclusive. It was suggested that further guidance, advice and best practice may be beneficial.
  • The significant resource implications of the regulations were raised repeatedly by some respondents.
  • The need for further clarity and consistency around terminology, parameters and timescales across a wide range of planning policy and guidance was identified.

Respondent views on the Partial / Interim Impact Assessments

The main consultation asked for views on a range of impact assessments which had been carried out. There was general agreement with these, with comments reflecting that many respondents didn't have a view or felt decisions were best left to the Scottish Government. Where there was disagreement, this tended to relate to the importance the respondent placed on the impact of the regulations and associated implementation of policy.

Specifically, 87% of respondents agreed with the Fairer Scotland Duty screening and the conclusion that full assessment wasn't required. A similar proportion (88%) agreed with the Strategic Environmental Assessment pre-screening.

Children and Young People's views on open spaces and play areas

Favourite ways to play

In the CYP survey, children and young people identified a range of different ways they enjoyed playing, with physically active and adventurous play being especially popular.

Quantity and sufficiency of local open spaces and play areas

Overall, respondents expressed a range of positive and negative perceptions with regards to the quantity and sufficiency of their local open spaces and play areas. Broadly speaking, primary school age respondents were somewhat more likely to be positive about the sufficiency of local spaces than secondary school age respondents.

Travelling to play areas

Children identified a range of ways they travelled to play areas. Respondents cited varying experiences in their responses, with some saying it was easy, but others saying it was difficult or specifying barriers in relation to travel and access.

Quality of local open spaces and play areas

Overall, respondents were most likely to identify seeing and making friends, having fun, and specific play equipment such as swings as being the best things about playing and hanging out in local spaces. Boredom, litter and broken or poorly maintained equipment were those most frequently seen as being negative aspects of their play experience. There were a range of positive and more negative viewpoints regarding the quality of local play areas and open spaces amongst respondents.

Frequency of playing outside

Overall, while many respondents feel that they play outside very often, a significant proportion would like to play outside more than they currently do. The most common barriers to playing outdoors were the weather, a perceived lack of things to do in local areas, and safety concerns.

Variety of opportunities and priorities for improvement

Overall, both primary school and secondary school age respondents identified a wide range of potential improvements to local open spaces and play spaces. In addition, the majority of secondary school respondents felt that their local areas did not have the right variety of spaces, places and activities. Having spaces to hang out with friends and opportunities to play sports were important priorities for change.

Other issues raised by respondents

There were some additional issues raised by respondents to the Children and Young People's survey which recurred in their responses to a range of different questions. These included:

  • concern around the lack of accessibility and inclusivity of play areas and open spaces for children with disabilities;
  • the proximity of spaces and the need to travel as a barrier to play participation;
  • a need for more indoor places to play in because of the role of the weather in making outdoor activities unappealing; and
  • the benefits of spending time in natural environments.



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