RESPONSES FROM THE OPEN SPACES SOCIETY

home page OSS RESPONSES TO CONSULTATION DOCUMENTS Some links to our responses, some summaries; sometimes both Where we have not provided the response on-line, it is available to OSS members on request.


June 2008	Department for Environment, Food and Rural Affairs Consultation on the draft Marine Bill We have warmly welcomed the coastal-access provisions in part 9 of the draft Marine Bill Response attached (pdf format)


December 2007	Defence Estates Dartmoor Training Area Environmental Appraisal We have expressed deep disappointment in the appraisal, which rejects all our proposals for mitigation and complacently endorses the status quo. We have said this reinforces our case for an independent review of military training needs in the UK and, in particular, for freeing national parks from damaging military training.


September 2007	Department for Environment, Food and Rural Affairs Proposed South Downs National Park While we are delighted that the public inquiry inspector has recommended that the South Downs National Park should be confirmed, we are deeply concerned at the proposed exclusion of the Western Weald (around Petersfield, Liss, Midhurst and Petworth) and other areas, and have called for the public inquiry to be reopened.


September 2007	Department for Environment, Food and Rural Affairs Consultation on proposals to improve access to the English coast We have supported Natural England’s recommended option of the new coastal access being a right within a broad corridor around the coast of England. Response attached (pdf format)


August 2007	Department for Environment, Food and Rural Affairs Consultation on implementation of the right to apply for orders to extinguish and divert public rights of way Without prejudice to our strong opposition to these measures, we have commented on the detail of the consultation. Response attached.


August 2007	Rutland County Council Draft rights of way improvement plan We have expressed deep concern that the council intends to ‘develop a priority system for categorising rights of way’ and to ‘identify key routes’. The council should categorise the problems (for instance ploughing and cropping, which are seasonal, should be dealt with swiftly so that those responsible don’t get away with it again the following year) rather than paths.


August 2007	Surrey County Council Draft rights of way improvement plan We expressed concern that ‘some form of prioritisation is essential’ and have said the council should prioritise types of problems and not the paths themselves.


August 2007	Cornwall County Council Draft countryside access strategy We expressed deep concern that the council considers there are paths ‘which are not needed for public use’ and that it puts paths in categories of ‘gold’, ‘silver’ and ‘bronze’. The council should categorise types of problems and not the paths themselves.


August 2007	Dartmoor National Park Draft management plan 2007-2012 We have called for the removal of significant conifer plantations. The excellent long-term vision, that military training damaging to national park purposes should cease, should become a short-term vision, and military training should be reviewed every five years.


July 2007	Monmouthshire County Council Draft rights of way improvement plan We have expressed concern about the implication that there will be prioritisation of paths, since all paths are important, and have suggested instead that the problems, rather than the paths, should be prioritised. We have asked for greater attention to be given to processing claims for the addition of routes to the definitive map of rights of way. We have strongly supported the use of the council’s enforcement duties and have urged the council to carry out more prosecutions when owners and occupiers break the law.


April 2007	Department for Environment, Food and Rural Affairs Consultation on the Protection of Common Land in England, Commons Act 2006 Part 3 of the Commons Act 2006 contains the new procedure for consenting to certain works on commons. We have argued that the system must ensure that commons remain open and unenclosed, and that the rights of the commoners and the public are protected. We want the exemptions from the consent procedure to be strictly limited. Click here to view a copy of our response (pdf).


October 2006	Welsh Assembly Government Revision of Technical Advice Note 16, 'Sport Recreation and Open Space' We have argued for policies in favour of protecting and enhancing public open space, for the benefit of local communities.

October 2006	Defra Widths on orders, Planning Inspectorate Advice Note 16 We have said that the use of the terms 'approximate', 'minimum' or 'maximum' widths for the creation of new paths, or the recording of existing highways, in path orders is unacceptable. The width and position of paths must be stated precisely.

October 2006	Bournemouth and Poole Borough Councils Bournemouth and Poole rights of way improvement plan We have given detailed comments on the plan, to promote and protect the interests of all public path-users.

October 2006	Defra Changes to game licensing and game management We have opposed a proposal to remove the restriction on shooting game on Sundays and christmas day because these days are, for many people, their only opportunity for quiet walk in the countryside, free from disturbance.

September 2006	North Somerset Council Draft enforcement policy for public rights of way We have congratulated the council on producing this policy. We have said that top of the enforcement priority-list should be ploughing and cropping since it needs to be tackled while it occurs. We are concerned the council does not intend to enforce against furniture on public rights of way where there is no evidence whether the furniture is legitimate, and have said it must enforce against all furniture which has no clear authority.

August 2006	Torbay Council Rights of way improvement plan We have expressed a number of concerns but we are pleased that Torbay considers its amenity open spaces to be a precious asset and that it is committed to preventing their loss.

August 2006	Welsh Assembly Government Clean Neighbourhood and Environment Act 2005, proposed regulations for gating orders We consider that gating orders should only be permitted in urban areas, that the authority must produce firm evidence that a gating order is needed and that the Open Spaces Society should be notified automatically of any proposed or approved gating orders. We have asked that the inspector for public inquiries into gating orders should be appointed by the Planning Inspectorate and not the local authority.

July 2006	Somerset County Council Rights of way improvement plan We have objected to the proposed policy to prioritise paths into categories and to consider the rationalisation of surrounding rights of way where appropriate.

June 2006	Brecon Beacons National Park Authority Rights of way improvement plan We are concerned at the proposal to create a hierarchy of paths for schedules of maintenance and improvement.

May 2006	Leicestershire County Council Rights of way improvement plan We have made a number of comments and in particular we support the council in its opposition to path rationalisation schemes.

May 2006	Telford and Wrekin Borough Council Rights of way improvement plan We have submitted a list of examples of what we would like to see in the plan.

April 2006	Defra Response to consultation on section 69 of the Countryside and Rights of Way Act 2000 We have made comments relating to the powers of local authorities to have regard to the needs of persons with mobility problems when authorising the erection of stiles etc on public rights of way.

March 2006	Powys County Council Interim development control guidance on wind farm development in Powys We wish to see the proximity to public rights of way included in the criteria for siting wind farms.

March 2006	HM Treasury Barker review of land-use planning We are concerned that the review potentially threatens the largely effective planning system and undermines the statutory duty for sustainable development. We wish to see the protection of open space addressed.

February 2006	Pembrokeshire County Council and Pembrokeshire Coast National Park Authority Rights of way improvement plan for Pembrokeshire We expressed concern at plans to prioritise public rights of way so that some get more attention than others.

February 2006	Norfolk County Council Draft rights of way improvement plan 2006-2016 We have emphasised the importance of the current highway authority duties, to get paths in good order and to update the definitive map, and said that difficult-to-use paths are likely to become well used once they are properly opened up.


February 2006	Defence Estates Access and recreation strategy for the Ministry of Defence estate We have called for full, public justification, in layman's language, where access and recreation cannot be facilitated on the estate. Non-statutory access opportunities are far inferior to statutory rights. We have urged the MoD to have a specific policy to dedicate land to public access under section 16 of the Countryside and Rights of Way Act 2000; this could also provide access for users other than walkers.


December 2005	Defra Countryside and Rights of Way Act 2000, section 68, vehicular access over common land and other land We submitted that, due to cases in the House of Lords (Bakewell v Brandwood), section 68 is now unsatisfactory. Section 68, which purports to allow vehicular access across commons and greens in certain circumstances, conflicts with legislation which outlaws action by landowners which interferes with the rights of commoners, and on village greens any activity which does not promote recreation and is not for the better enjoyment of those using the green.


December 2005	Defra Consultation on the confirmation of by-laws relating to countryside recreation Defra proposes to change standard models of clauses which can be used to control public behaviour. We considered that many essential clauses were omitted, such as those concerning vehicles. We were concerned that the proposed fast-track system for gaining Defra's approval for by-laws should include public advertisement.


December 2005	Crown Office of the Deputy Prime Minister Applying the Planning Acts to the Crown Office of the Deputy Prime Minister We strongly support part 7 of the Planning and Compulsory Purchase Act 2004 which requires the Crown generally to apply for planning permission for a development. In our response to the draft circular we argue that the Crown should be treated like any other applicant, and that exemptions for national security should not apply in the national parks except in exceptional circumstances.


November 2005	Defra Consultation relating to the amendment of the Local Access Forums (England) Regulations 2002 See our response.


November 2005	Defra Public consultation on introduction of New Environmental Impact Assessment (Agriculture) (England) Regulations We are concerned that Defra proposes to raise the thresholds for projects regarding the conversion of uncultivated land and semi-natural areas so that it could become easier to carry out adverse activities. We have made a number of proposals to protect such land.


November 2005	Defra Consultation on the diversions of rights of way: (1) for the protection of Sites of Special Scientific Interest (SSSIs); and (2) temporary diversions for dangerous works The Open Spaces Society has commented on the detail of the forms which will be used for diversion applications under the new provision in the Highways Act which allows the diversion of paths for the protection of sites of special scientific interest and temporary diversions for dangerous works. Our comments aim to make the proposals as clear to the public as possible and to reduce the instances where the new provisions can be used. In particular we have argued that English Nature should bear the cost of public path orders for SSSIs rather than local authorities.


October 2005	Welsh Assembly Government Welsh national park authorities draft policy statement We have expressed concern that the statement does not address the role of the Welsh Assembly Government as a champion for national parks, nor does it deal sufficiently with the role of bodies other than the national park authorities in promoting and having regard to national park purposes. The statement should emphasise more strongly the importance of the parks to Wales as a whole and in particular to its cultural heritage.


October 2005	Defence Estates Draft defence estate strategy 2006 While we broadly welcome this, we are concerned that it appears to be self satisfied and complacent, not recognising the huge challenges of the need to reduce and remove damaging military training from areas of important landscape, archaeology, recreation and enjoyment by the public


September 2005	Home Office Gating order powers under section 2 of the Clean Neighbourhoods and Environment Act 2005 We have made a number of proposals to limit the effect of these proposals and protect the public interest. See our response. The closing date was 16 September 2005. View the consultation document.


September 2005	Warwickshire County Council Draft countryside access and rights of way improvement plan We have urged the council to refuse to make orders to alter paths when the changes are of purely private benefit; we have opposed high priority being given to orders to alter paths through school grounds and in areas of high crime, and we do not agree that, where there are obstructed routes with non-definitive alternatives, landowners should be advised to apply for a diversion, and we have called for landowners to be required to reopen the paths instead.


September 2005	Welsh Assembly Government Consultation on the Environment Strategy for Wales We have expressed concern at the encouragement given to wind turbines in the Welsh countryside; we have welcomed the references to common land; we have urged the assembly to encourage communities to register land as a new green to protect it from development, and we have called for swift action to reopen and waymark existing public rights of way of which, in Wales, only half are easy to use


June 2005	Oxfordshire County Council Draft rights of way improvement plan We have welcomed the plan, the vision statement and the key themes and outcomes, but are concerned that the nine principal outcomes have not been prioritised and that two of them are statutory duties which should not be presented as something new. The council notes that many of these things cannot happen without increased resources and we have said that the plan must be used to persuade councillors to put more money into rights of way.


April 2005	Cambridgeshire County Council Draft rights of way improvement plan While welcoming the care taken in producing the document we are concerned that the council is hoping to process packages of path changes, and will give greater weight to the views of local people than those from further afield. We fear that such packages will be contrary to the interests of the wider public, on whom the county depends for income.


March 2005	Bedfordshire County Council Outdoor access improvement plan While supporting much of the plan we have criticised the council for being ‘prepared to consider changes to the network that landowners might seek as corollaries to agreements’ to create routes, since this plan is about access improvement not trade-offs. We dispute the council’s claim that users ‘must accept it is not always realistic to comply fully with the statutory duty to keep all paths in all parts of Bedfordshire in an easy to use condition at all times’ since we consider that it is the council’s legal duty to do this. We are concerned about proposals to create a hierarchy of routes since every path is important.


March 2005	Defra Draft Natural Environment and Rural Communities Bill We generally support the Natural Environment and Communities Bill but have a few comments to make. See our response.


February 2005	Devon County Council Devon on the Move - rights-of-way improvement plan In our response we have criticised the draft plan for its emphasis on moving paths around instead of getting all public rights of way in good order and the definitive map up to date, as the law requires, and for relying on misleading information. We have called for much of the plan to be rewritten.

October 2004	Welsh Assembly Government TAN8 Renewable energy We are concerned that a judgment has been made in favour of on-shore wind energy with only a superficial look at alternatives. We feel there is insufficient recognition in national policy documents of the importance of common and other access land and of natural parks, and the adverse effect of wind turbines on the enjoyment of the countryside. There should be a presumption against development of wind turbine sites on common land and designated areas.

September 2004	Defra Consultation on clean neighbourhoods We have been asked to comment on whether there should be a new, free-standing provision to enable certain alleyways to be gated without removing the status of the highway, where there are serious problems with crime and anti-social behaviour. There is a list of conditions which would need to be met. We have said we do not agree with the measure because gating alleyways will exacerbate the problem rather than provide a solution. The result will be uncertainty for the public who will not know when a route is available to them and it will force people into cars instead of using short cuts away from traffic.

September 2004	Department for Transport Local Transport Note 2/04 Adjacent and shared facilities for pedestrians and cyclists We have welcomed the advice note but expressed concern about the references to permissive cycle routes which we oppose. We have called for a presumption that pedestrians and cyclists will be segregated except where there is overwhelming evidence that this is not necessary.

September 2004	Defra Cap reform implementation: consultation on proposed and possible measures for implementation of cross compliance in England (single payment scheme) A summary of our response.

August 2004	Office of the Deputy Prime Minister Consultation on best value performance indicators for 2005/06 We have supported the continuation of the existing best value indicators for public rights of way (BV178), we have asked for BV119 to be amended to include common land so that the indicator is ‘the percentage of residents satisfied with the local authority cultural services:…parks, open spaces and common land’ and we have called for a new performance indicator: ‘the percentage of registered common land which is free of any encroachment’, so that local authorities would be required to survey the commons in their area and record any unlawful encroachments.

July 2004	Houses of Parliament, Joint Committee Draft Charities Bill In our response, the Open Spaces Society has commented on the draft bill and, in particular, on the meaning of charitable purposes.

April 2004	Defence Estates Review of In Trust And On Trust, Defence Estates’ strategy We have, among other things, renewed our calls for an independent review of military training needs in the UK with a view to freeing our top landscapes and access areas from military training; we have suggested ways of improving and increasing public access to Ministry of Defence (MoD) sites, and we have called on MoD to recognise its statutory duty to have regard to national park purposes.

March 2004	Defra Use of mechanically propelled vehicles on rights of way In our response, the Open Spaces Society agrees with government that better use should be made of existing powers to curb illegal use of public rights of way by mechanically propelled vehicles, and that adequate resources should be provided to encourage local authorities to use traffic regulation orders where appropriate. However, we deplore government’s attempt to do away with the legitimate rights of vehicular users on byways, by proposing a cut-off date of one year after which any unrecorded rights of way for vehicles shall be recorded as restricted byways, and therefore the vehicular rights will be lost.

January 2004	Wiltshire County Council A framework for managing the rights-of-way network in Wiltshire 2003-2008 While welcoming the proposed increase in budget for public paths, we remain concerned at the number of paths still illegally obstructed, and that the definitive map still has many anomalies. We also deplore the proposed ‘hierarchy’ of routes and propose an alternative means of determining priorities according to the type of problem. We fear the hierarchy will lead to many lesser-used paths disappearing completely.

January 2004	Office of the Deputy Prime Minister Removing Plan Requirements We have opposed the proposal to exempt so-called 'excellent' authorities from the duty to produce a rights-of-way improvement plan. The plans will be important in ensuring that authorities carry out much-needed improvements to their path networks. The plans are to become part of the Local Transport Plans from 2005 onwards, thereby ensuring that additional funds will be brought into rights-of-way. In any case, no authority is 'excellent' when it comes to rights of way, none has an up-to-date definitive map and all have a significant proportion of paths which are difficult to find and use.

January 2004	Defra Proposed amendments to legislation when 'roads used as public paths' are reclassified as restricted byways The society supports the proposed amendments to legislation which will accompany the reclassification of roads used as public paths as restricted byways. We have made a few additional suggestions such as using this as an opportunity to remove the powers of the magistrates' courts to authorise the stopping-up or diversion of any paths shown on the definitive map.

December 2003	Office of the Deputy Prime Minister Sustainable Development in Rural Areas, Planning Policy Statement 7 (PPS7) The draft PPS7 does not fulfil the government's stated aim to provide a clear, up-to-date statement of national planning policies for rural areas, to ensure that the planning system helps to facilitate sustainable development, and to protect the countryside. It is essential to include an unambiguous statement that the countryside should be safeguarded for its own sake otherwise the protection of the countryside will be weakened. It is vital that there is greater emphasis on opportunities for enjoyment of the countryside. The protection afforded to national parks and AONBs needs to be strengthened.

November 2003	Defra Consultation on agricultural use and management of common land This consultation paper follows the report of the government’s stakeholder working group on common land Agricultural use and management of common land. We have welcomed much in the consultation but remain concerned that promoting sustainable agricultural use and management may be to the detriment of public access, the amenity value of commons and their preservation as open and unenclosed land. Further consideration needs to be given as to how to involve the wider public interest in the sustainable management of commons and to ensure the public has a say in how commons are managed and protected. We consider that the regional advisory bodies should be statutory and not non-statutory as proposed by Defra.

August 2003	Institute for European Environmental Policy Evaluating the impacts of hill farming in England We have said that current practices of outwintering stock and feeding them on the commons leads to poaching of the ground which is unpleasant for visitors. Where there is overgrazing, or undergrazing, and it is thought that this is wrong, fencing is often seen as a solution but this is a physical and psychological barrier to access. We wish to see far less fencing of common land, and removal of existing encroachments, and we advocate use of shepherds as an alternative which would also benefit the rural economy

July 2003	Defra Foot and Mouth response Protocol for restrictions on public rights of way and access to open country in the event of an outbreak of foot and mouth (FMD) We welcome the positive approach of maximum public access and the least restrictions necessary, and the exhortation to highway authorities to use their powers to take action against anyone displaying misleading notices on a public right of way, and we ask that this be extended to access land. Standard notices with the Defra logo must be used. The prohibition of people from an infected area must be subject to the written consent of the secretary of state. Defra must be given powers to require a landowner to disinfect premises within a specified time. The protocol should repeat the advice in the Defra and Planning Inspectorate advice note 15 that a break in user of a route caused by FMD does not constitute an 'interruption' for claiming a path for the definitive map and, similarly, that a break in user of land due to FMD restrictions does not constitute an interruption when claiming land as a town or village green.

June 2003	National Assembly for Wales Review of national parks in Wales The two national park purposes must retain their primacy. We would not wish to see any upgrading of the social and economic duty. National park authorities must remain as planning authorities since planning powers are vital in upholding national park purposes and promoting sustainable development. We would oppose direct elections to national park authorities since this would mean that the national interest would be swamped by the parochial, and the parks are for the nation not merely those who are fortunate enough to live there.

May 2003	Defra Review of the overgrazing and unsuitable supplementary feeding cross-compliance controls in England We have said that the lack of legislation to create statutory commoners' associations who can regulate grazing for the wider interest limits the effectiveness of the current system for enforcing overgrazing controls. We have welcomed proposals to inspect all upland commons as entire units every three years. We have called for a ban on supplementary feeding on common land and we have said that fencing of commons is not a solution to overgrazing.

December 2002	Cabinet Office Strategy Unit Private action, public benefit: review of charities We have commented on the proposed purposes of charities, pressing for the inclusion of informal recreation

December 2002	Office of the Deputy Prime Minister Review of the planning enforcement system in England We consider there should be a duty on local authorities to instigate enforcement action, particularly regarding illegal encroachment on common land. There must be proper funding and training for local authority staff to ensure that enforcement action is taken.

November 2002	Defra Correcting errors in maps We have no objection to the proposals to enable the Countryside Agency to correct minor errors in draft and provisional access maps produced under the Countryside and Rights of Way Act 2000.

October 2002	Countryside Agency Arrangements for a national trails trust. We have not objected to the formation of the trust but are anxious that the emphasis for highway authorities is on getting all rights of way in good order. We do not want to see highway authorities' funds diverted into managing national trails. We have also expressed reservations about funding of national trails by third parties because this could lead to inappropriate sponsorship with unsightly advertising.

October 2002	Welsh Assembly Government Walking and cycling strategy for Wales. The Open Spaces Society has suggested ways of making walking and cycling more attractive and has called on the assembly to ensure all public paths are in good order.

October 2002	Greater London Authority Draft London plan. The Open Spaces Society, whose founders were particularly concerned with threats to commons around London and which was at the forefront of the campaign to save London open spaces from development, has responded to this consultation. We have called for better definition of the terms ‘open space’ and ‘metropolitan open land’. We want special mention of the need to retain existing playing-fields and commons and, where practicable, to provide new playing fields. We have commented that for cycle routes, where there is inadequate room for separate paths for walkers and cyclists, or a clear division between them is not possible, cyclists should be compelled to walk. Certain long-distance views from London should be designated.

September 2002	Defra Enforcement of highway authorities’ duty to prevent obstructions on rights of way (section 63 of the CROW Act). The Open Spaces Society has welcomed the introduction of this section of the CROW Act which we consider to be the most important and urgent section in part II. It will enable members of the public to serve a notice on highway authorities who fail to take enforcement action against illegal obstructions on rights of way. We have made detailed comments on the wording of the forms and have called for the scope of the section to be widened to include a number of abuses of rights of way such as disturbance of the surface without lawful authority (including ploughing), obstruction by crops, felling of trees, electric fences, badly maintained stiles or gates, and stiles and gates without lawful authority. We regret that the section does not include buildings, caravans and vehicles, and hope the government will find time in due course to amend this provision so that it does include them.

September 2002	Defra Crime Prevention on Rights of Way Public consultation paper on the designation of areas and other procedural matters. In our response the Open Spaces Society does not believe any provision is necessary to designate areas where it may be easier to close or move paths on alleged grounds of crime. The society argues that provided routes are welcoming, well lit and clean, they are a defence against crime, not a cause of it.

September 2002	Defra England Rural Development Programme - access review. In our response the Open Spaces Society considers that new public access must be an integral part of any agri-environment scheme; it must be permanent, of good quality and well publicised. A requirement must be that all public rights of way on the applicant's land are in good order before the grant is given and if they are later found to be blocked or abused, the grant is withdrawn. Defra must set up a procedure whereby all paths and access land on an applicant's holding are checked before grant is paid and regularly checked thereafter.

August 2002	Welsh Assembly Government Countryside and Rights of Way Act 2000 Rights of Way Improvement Plans (ROWIPs) Draft guidance to local highway authorities in Wales.
	In our response the Open Spaces Society urges that the top priority is for local highway authorities in Wales to get all their rights of way in order and the definitive maps up to date, and not to get deflected into producing business plans. However there is scope for creations to improve the network but these must not be swaps or trade-offs.

August 2002	Defra Common Land Policy Statement 2002.
	Our response to the policy statement from the Department for the Environment, Food and Rural Affairs and the National Assembly for Wales on common land, following the consultation in 2000 on 'Greater protection and better management of common land in England and Wales'.

June 2002	DTLR Electoral registers - access, supply and sale. The Open Spaces Society is concerned at the proposed limited availability of the full electoral register as it, and other path users, need the information for claiming paths for the definitive map and for prosecuting landowners who block public paths. It has called for user groups to be permitted electronic access to the full electoral registers.

June 2002	The City of Salford Alleygater's guide to gating alleys. The Open Spaces Society strongly opposes the council's policy of allowing alleyways to be closed, and its guide which encourages this practice. The society argues that closing alleyways will not reduce crime, in fact it will probably have the opposite effect. The legal advice in the document is flawed.

June 2002	Welsh Assembly Government Proposals for new regulations on voluntary dedication of access land under section 16 of the Countryside and Rights of Way Act 2000. The Open Spaces Society supports the proposals for implementation of section 16 and wants it to be made as easy as possible to dedicate access land voluntarily, and for such dedications to be well publicised.

June 2002	Welsh Assembly Government Countryside and Rights of Way Act 2000, Proposals for new regulations on restrictions on access to open country/registered common land for land management and other purposes. The Open Spaces Society supports the least restrictive option and any measures to minimise closures and restrictions and to assist the public in knowing about them and understanding them. The public should have a right to be heard at appeals against the refusal of applications for closures and restrictions.

May 2002	Defra Rules for procedures for inquiries and hearings held under the Highways Act 1980, Wildlife and Countryside Act 1981 and Town and Country Planning Act 1990. The Open Spaces Society opposes rules for inquiries because they will prejudice the public. Rules and formality are off putting to inexperienced people. We object to it being mandatory to submit evidence ahead of the inquiry because lay people often do not have the time or resources for this.

April 2002	DTLR Possible changes to the use classes order and temporary uses provisions.
	The Open Spaces Society favours a reduction in the number of days for temporary uses of land without planning permission as this will ensure that green space can be used by the public on more days. The Open Spaces Society proposes a new rule of no permitted development rights for activities in common land, village greens and other open space.

April 2002	National Assembly for Wales Planning, delivering for Wales.
	The Open Spaces Society welcomes the commitment to retaining the fundamental structure of the planning system but is concerned at the emphasis on speed and process to the detriment of a transparent system with greater community involvement.

April 2002	Defra Proposals for regulations on dedication of access land under section 16 of the Countryside and Rights of Way Act 2000.
	The Open Spaces Society wants to make it as easy as possible for landowners to dedicate land as access land. It considers that grant should not be available for dedicating the land, but for managing the land. A condition of any grant must be that the landowner enters into a management agreement which binds him not to undertake activities which could damage the land. Any dedications must be well publicised.

March 2002	Defra Draft guidance to local highway authorities on the preparation of rights of way improvement plans.
	The Open Spaces Society wants to see the improvement plans bringing genuine improvements to the network, and to provide for path creations, not path trade-offs. The society is concerned that the plans won't be much use while the path network is in such a poor state, and therefore there should be guidance setting out how local authorities must comply with their legal duties to get paths open and definitive maps up to date.

March 2002	Defra Proposals for regulations on the exclusion or restriction of access to open country and common land under the Countryside Rights of Way Act.
	The Open Spaces Society supports the least restrictive option and any measures to minimise closures and restrictions and to assist the public in knowing about them and understanding them. The public should have a right to be heard at appeals against the refusal of applications for closures and restrictions.

March 2002	Countryside Agency Proposals for guidance on local access management, exclusions and restrictions.
	The Open Spaces Society supports the least restrictive option and any measures to minimise closures and restrictions and to assist the public in knowing about them and understanding them.

March 2002	DTLR Compulsory purchase and compensation.
	The Open Spaces Society’s main concern is about proposals to amend or repeal provisions which require suitable exchange land to be given when common land or open space is compulsorily purchased.

March 2002	DTLR New parliamentary procedures for processing major infrastructure projects.
	The Open Spaces Society is deeply concerned that allowing parliament to approve major infrastructure projects in principle will remove the public’s right to debate the principle of development at a public inquiry. It is essential that those most affected by major development proposals should have a right to question both the need for it and its location. We therefore oppose the government’s proposals.

March 2002	DTLR Planning: delivering a fundamental change.
	The Open Spaces Society welcomes the paper’s aim to deliver a transparent and efficient system, with greater community involvement, but considers this will not be achieved by the proposals. We are concerned at the emphasis on speed rather than quality and detail, the lack of public involvement, abolition of structure, unitary and local plans and the opportunity to be heard at public inquiries.

March 2002	DTLR Reforming planning obligations.
	We accept that the system needs to be transparent. The obligations alone should not be relied upon to deliver sustainable development. All plans should deliver sustainable development. However the obligations should be designed to deliver benefits over and above sustainable development.

March 2002	Inquiry into the lessons to be learnt from the foot and mouth disease outbreak of 2001.
	Closing the countryside was a disaster. In future outbreaks of animal disease there must be no wholesale closure of paths, paths must be reopened as quickly as they are closed, misleading signs on public paths must be removed and the people responsible prosecuted by the highway authority, highway authorities who refuse to reopen paths quickly should be required to do so by government, vaccination should be piloted on certain flocks and there should be a national access database.

March 2002	Defra ERDP Agri-Environment Schemes - Access Review. (January 2002)
	The Open Spaces Society advocates that whenever public money is paid, rights should be created in return, either by path creation agreement or by dedicating land to access. No public money should be given to any landowner or occupier unless all the public paths and access land on the land he owns or manages are in good order. Agri-environment schemes can provide funding for the management of access but must not fund access per se.

March 2002	National Assembly for Wales Proposals for regulations on provisional and conclusive maps of open country and registered common land.
	The Open Spaces Society is particularly concerned that anyone who wishes to appear at an appeal by a landowner into the inclusion of land on draft maps, should be entitled to be heard.

February 2002	Countryside Agency South Downs National Park.
	The Open Spaces Society supports the South Downs campaign group’s submission on the draft boundary. OSS calls for arrangements, under the existing legislation, which will protect the integrity and recreational value of this area.

February 2002	Defra Proposals for regulations on provisional and conclusive maps of open country and registered common land.
	The Open Spaces Society is particularly concerned that anyone who wishes to appear at an appeal by a landowner into the inclusion of land on draft maps, should be entitled to be heard.

January 2002	House of Commons Select Committee for Transport, Local Government and the Regions Inquiry into road traffic speed.
	The Open Spaces Society ad