In November the City Council launched a consultation on three news Supplementary Planning Documents (known colloqually as SPDs). Although the consultation period has now ended, you can still see the draft documents on the Planning Consultation pages of the Council website.
This is the response of the Coventry Society to the consultation on the Open Space SPD.
This is a fairly standard document but which needs some rejigging – and extra information – if it is to do what it says in the first paragraph of the Executive Summary.
For example :
1. the Sections 6 and 7 (Open Spaces and the Water Environment and Biodiversity and Green Infrastructure) look like add ons and are not well incorporated in the document since there are no references to these sections in the Executive Summary or the Overview.
2. There is a reference to the improvement to archaeology in the first paragraph of the Executive Summary but no further reference elsewhere in the document as to how green spaces can help retain or protect archaeology. How is this then a Summary? If archeology is not considered important then why reference it at all?
It is welcome that the document displays a policy integration with the Councils 2019 Green Space Strategy and takes the definitions, typology and hierarchy of green space from it. However, the document seems to ignore other Council policy documents referenced in the text (e.g. Urban Forestry Strategy, Playing Pitch Strategy ) and yet which are held to be ‘material planning considerations when assessing proposals’. The significance of these Strategies need demonstrating.
The document is prosaic – it doesn’t seek to raise the significance of green and open spaces. From our perspective open spaces are a key part of placemaking and in ensuring places are distinctive, beautiful, inclusive, greener, healthier and more resilent to climate change. They support twenty-minute neighbourhoods with access to open space and places to play.
Executive Summary
Third para needs an addition at end ‘or in the city centre inside the Ring Road’, in order to properly reflect the wording in para 4.15 (p14)
Overview
Para 1.3 needs to start ‘Well planned and maintained open spaces can…’ as ‘It’ can be taken to refer to the foregoing para referencing new development
Para 1.4 First sentence is contentious and unnecessary.
This Overview needs to link to S6 (notably SUDS and the need for additional water storage in greenspaces (6.32) and S7 (esp 7.4 and the introduction to 7.6).
Benefits of Green and Open Spaces
A number of the paragraphs focus on the Marmot Review and its important outcomes. Bringing this section up to date – and further emphasing the importance of open spaces – needs to refer to the realisation, through the current Covid-19 pandemic, of the importance of opportunities to connect with nature and enjoy play and recreation in natural settings. Looking forward, open spaces are important in helping tackle the climate emergency and the biodiversity crisis.
We would wish to see a greater recognition of the importance of green and open spaces. Open spaces are a key part of placemaking and in ensuring places are distinctive, beautiful, inclusive, greener, healthier and more resilent to climate change. They support twenty-minute neighbourhoods with acces to open space and places to play.
Para 1.15 need to separate out ‘Alleviation of flood risks’ from ‘Instilling unique character to areas and providing local identities’. An additional benefit which should be added is ‘supporting early years developoment and education’.
Local Policy
In 2.8 is there a LP policy on footpaths and bridleways? The importance of these features to access green and open space is scarcely acknowledged, and there is no reference to ensuring their retention or developoment in association with creating new green and open spaces.
While the document references (later) standards from the Green Space Strategy are there no standards or policies that can be derived from the Urban Forestry Strategy or Playing Pitch strategy? If not then why are they mentioned here?
Green Space and Open Space definitions and recommendations
Sections 3.6-3.8 focus on equipped play areas. They ignore the guidance from Fields in Trust on playing pitches and outdoor sports. Why? Surely such provision could and should be made in relation to larger development sites?
3.8 is fundamentally wrong. Fields in Trust guidance is for the distances of playgrounds from residential properties to be a maximum not a minimum! How far have young parents to take their children to play?!
The Planning Process : how development must contribute
Para 4.15 refers to exceptional circumstances where off-site contributions are needed. These are not set out clearly, however. Derived from the rest of the document, they appear to be
– site is too small (4th para of Summary and 4.11)
– demonstrable surplus of existing open space in a locality (4th para of Summary only?)
– development inside the Ring Road ( this para).
This para needs to be expanded to reflect the circumstances that are regarded as exceptional.
Para 4.16 is under heading Securing Delivery. This should be the first para in the next section ‘Implementation’.
Implementation
Para 5.3 introduces a key requirement for developers i.e. POS must be completed to the Councils reasonable satisfaction before 50% of houses are occupied on site. This is signifcant information for developers. It surely needs a justification and a reference in the Executive Summary.
Sections 6 and 7 appear standalone and appear to have come from external sources. They are not at all well integrated into the document. If they are to be taken seriously by developers in their development proposals then they need to be referenced in the Executive Summary and the Overview. See earlier comments.
Coventry Society