Local Open Spaces Assessment
Staines Town Society welcomes the proposed Local Green Space assessment, as introduced by the NPPF to give a higher degree of protection to areas of importance to local communities, especially as the existing PUOS designation is outdated and has proved ineffective. Spelthorne does not have extensive open space and so these smaller areas are particularly valuable to local people, and deserve protection from the unremitting pressure by Government and commercial interests to cram housing into every corner.
It would have been useful to have a list of the sites proposed as part of the Issues and Options consultation, to check that the methodology is suitable for them.
We agree that the assessment must be rigorous if the designation is to resist challenges. However we wish to make the following comments on the consultation draft.
2.5 states that private land without public access will generally not be included. This should include visual access, which can give enjoyment. For example, people living in houses backing on to playing fields, e.g. at Matthew Arnold School and ex-Brooklands College site, have the pleasure of looking out on to green fields.
2.8. The meaning of this is not clear: from whom is evidence required? The Council may usefully invite residents to send in photographs and other evidence, but it is not reasonable to put the burden of proof entirely on the public. We assume that officers will investigate and collect necessary evidence, as they do for other Local Plan documents.
2.13. Sites in the Green Belt are already protected, but the methodology should state that any site removed from the Green Belt in the ongoing GB assessment should then be considered for Local Green Space designation.
3.2. The historic significance scores are too low. It is absurd that having frequent disturbance scores 2 but being in a Conservation Area only scores 1. The ‘positive contribution’ requirement is unnecessary. If a site is in the setting of a listed building or ancient monument, or is in a Conservation Area or an area of archaeological potential it should score 3, and if it satisfies 2 or more of these criteria it should score 5.
3.3. We agree that more isolated sites may be very important to their neighbourhoods and as such
should score more highly.
Access should include visual access, cf 2.5.
Many recreational sites will have a mixture of free and charged facilities. We assume this does not debar them from scoring 2,3, 4, or 5 on recreational use. Officers should collect evidence of use if needed.
3.4 Much of the evidence, e.g. of being SSSI or LNR, already exists. Officers should note it and collect any further evidence needed, in consultation with Spelthorne Natural History Society and relevant others.
3.5. We do not object to the tranquillity scores, but feel that scores in other categories should be raised to match them.
3.6, 3.7 Total score 13 is too high and will eliminate some sites which are important to their local communities. We suggest 9 or 10.
3.9. This contains an error. 0.25 ha is 2,500 sq.m., the size of about 12 residential plots, not one. Even 250 sq.m. would be excessive, as residential plots are rarely as much as 200 sq.m. now. There are not many applications for single houses, but e.g. 19/00435/FUL, the old pumping station, is 197 sq.m. (refused, but not on plot size) and 19/00075/FUL, the storage shed behind the Blue Anchor, is only 39 sq.m., admittedly an extreme case. 2,500 sq.m. is far too large a lower limit and would eliminate some valued sites.
We suspect that 0.25 ha is a misprint for 0.025 ha, and suggest that 0.02 ha or 0.015 ha would be more appropriate, if a lower limit is necessary.
For the above reasons Staines Town Society objects to the draft methodology in its present form.
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