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Archive | December, 2022

PSPOs for the Dog Control in the Forest (and what the Kennel Club say about PSPOs)

New Forest District Council has sent two draft Public Spaces Protection Orders (PSPO) , which we broadly support, for public consultation. The first to ban the lighting of fires and use of BBQs (principally on the Crown Lands), and the second to ban the feeding and petting of ponies, horses, mules, and donkeys in the open areas of the New Forest. The consultation runs for nearly 8 weeks from Monday 6th December 2022 to Friday 27th January 2023.

In this fifth in the series on PSPO’s we give our recommendations For a Draft Dog Control PSPO, how they stack up against existing guidance, and What the Kennel Club Says About PSPOs.

Kennel Club and PSPO:
When PSPOs were first introduced to replace Dog Control Orders in the Anti-social Behaviour, Crime and Policing Act 2014, the Kennel Club were supportive of their use for irresponsible dog owners under the previous Dog Control Orders, but worried chiefly about the impact on responsible dog walkers, and unhappy with how some councils brought them forward.  2015 DEFRA guidance added dog law and welfare experts to the list of PSPO consultees which already included the Kennel Club.  In their 2016 report on PSPOs “Out Of Order – The Impact Of Access Restrictions On Dogs And Their Owners” the Kennel Club cite instances of councils imposing orders without deeming consultation necessary, a council erecting restriction signage before the consultation had finished, and councils either not including exemptions for registered blind people and assistance dogs or not providing suitable alternative space where their needs could be met.

In 2018 they trumpeted a victory over legal challenge of overly broad language in Richmond dog’s PSPO.

The parts of the order which were successfully challenged and which were quashed included that a person could be found guilty of an offence if their dog ‘causes an annoyance to another person or animal’ or ‘causes damage to any Council structure, equipment, tree, turf or other Council property’, which could include damage to grass from urination.[*]

While the language is indeed questionable, there seems no evidence that anyone was ever charged with “lawn damage”.  The judge ruled that the annoyance provision added nothing to the provision on keeping a dog under control, and that there was insufficient evidence to demonstrate a need for the prohibition on causing damage as defined in the order. The restriction limiting dog numbers per walker was upheld at 4, although 18 professional dog walkers may be licensed for 6, and residents may walk up to 6 under a permit system.  Currently 12 of the 18 available Richmond licenses are in use.

Many of the Kennel Club’s initial reservations seem to have now been addressed.  Councils uniformly carry out consultation on PSPOs and include exemptions, some go as far as carrying out Equality Impact Assessments to show that no group is unduly disadvantaged by the order.  Their chief concerns continue to be any blanket restrictions that require full time use of leads, restrictions to areas insufficient for needs of local walkers, lack of suitable alternatives and possible displacement to less appropriate areas by those avoiding the restrictions.

 

Our Recommendations:
In creating our recommendations for a Dog Control Public Space Protection Order for the New Forest we reviewed over 50 PSPOs enacted throughout the country, Kennel Club guidance for their members subject to PSPO rules, and most importantly the New Forest Dog Walkers Code, voluntary guidance approved and partially authored by the stakeholders in the New Forest Dog Forum, including the local New Forest Dog Owners Group (NFDOG).

These are our suggestions for rules that may be enforced through a PSPO:

  • Lead “by direction” — this mirrors existing Forestry byelaw which says if an authorised officer (i.e. Forest Ranger, etc) asks someone to put their dog on lead, they should.
  • Leads required in ground nesting bird season in those areas where FC have put “red zone” signs close to curlew and other specific territories.
  • Leads required on portions of the proposed England Coast Path that are adjacent to fields with livestock, or adjacent to important coastal habitats.
  • Out of control dogs worrying/chasing/attacking livestock.
  • Persistent dog fouling of car parks and paths.
  • Leaving bagged faeces (Littering).

We’ll consider these each in turn as to how they stack up against the Dog Forum and Kennel Club guidance, and other PSPOs throughout the UK.

 

Lead “by direction”

Kennel Club Guidance:
Dogs on lead by direction
‘Dogs on lead by direction’ orders require owners to put their dogs on a lead when instructed to by an authorised officer. Enforcement officers could include parks police or a dog control officer. These measures allow responsible dog owners to exercise their dogs off lead without restriction – providing that their dogs are under control – whilst giving local authorities the power to restrict dogs not under control.
New Forest Dog Walkers Code:

  • Carry a lead for each dog in your care.
  • Keep dogs on leads in and around car parks and alongside roads.
  • Always keep all dogs under effective control; if you cannot reliably and quickly call your dog back to you and away from people or other dogs, please keep it on a lead.

This is one of the most standard PSPO restrictions, and existed previously under many Dog Control Orders.  It also echoes Forestry Commission byelaw 5.xiv. “No person shall in or on the lands of the Commissioners: … on being requested by an officer of the Commissioners, fail to keep the dog on a leash;” [†]  The Kennel Club support these orders as they allow responsible dog owners who keep their dogs under control to exercise off lead.

 

Leads required in ground nesting bird season in those areas where FC have put “red zone” signs close to curlew and other specific territories.

Kennel Club Guidance:

Dogs on lead
Orders which require owners to put their dogs on leads in certain areas often do so for the safety of dogs, their owners, and other nearby members of the public. These measures may apply to car parks, pavements near the road, and picnic areas. We can support reasonable ‘dogs on lead’ orders when used in a proportionate and evidence-based way.

Blanket ‘dogs on lead’ restrictions can prevent dog owners and their dogs from getting their appropriate daily exercise, including ‘regular opportunities to walk and run’ – which in most cases, will be off the lead while still under control.

Kennel Club on Displacement and Wildlife[ ]:

Another common unintended consequence is displacement onto inappropriate land, typically land where livestock or sensitive wildlife is present, resulting in new conflict being created.

Thanet Dog Control PSPO:

6. Failing to protect wildlife

A person in charge of a dog shall be guilty of an offence if, at any time, within the administrative area of the Authority, they fail to protect wildlife by allowing dog(s) and humans to interfere with, trap or attempt to trap or snare, chase or disturb any wildlife on council owned or controlled land.

New Forest Dog Walkers Code:

  • Keep your dog to the main tracks when birds are nesting on the ground (usually March – July).

Again this suggestion is echoed in Forestry Commission byelaws 5. “No person shall in or on the lands of the Commissioners: xii. permit any animal in his charge to be out of control; xiv. permit a dog for which he is responsible to disturb, worry or chase any bird or animal…;” [§] Some existing Dog Control PSPOs directly include a failure to protect wildlife offence (i.e. Thanet). The Kennel Club raises concerns with restrictions or exclusions which lead to displacement to more sensitive areas, arguably an understatement that the New Forest SSSI is such an area.  It is doubtful that the Kennel Club would shirk seasonal restrictions to a small portion of this protected habitat as they clearly recognize the need to keep walkers to more appropriate access areas.

 

Leads required on portions of the proposed England Coast Path that are adjacent to fields with livestock, or adjacent to important coastal habitats
The incredibly delicate and high value of the New Forest’s coastal habitats have unfortunately shown many of the shortcomings in the England Coast Path as defined by legislation.  Because of this, the Highcliffe to Calshot stretch of the path has still not been approved by the Secretary of State. (Our ongoing discussion of these wider Coast Path issues may be found here.)

The England Coast Path proposal creates potential new access to previously undisturbed areas. Although the proposals already include some stretches that Natural England say require leads, they have ignored their own guidance regarding livestock, and ignored potential damage to our most sensitive coastal habitats.  We think the most comprehensive solution would be to require dogs to be put on leads for all sections adjacent to fields with livestock or areas of habitat conservation value.  This would protect Forest stock on back up grazing, and areas for breeding or over wintering bird populations that are key elements of the New Forest’s legal conservation designations.

While the Kennel Club guidance does not go as far as this very specific instance, it is reasonable to apply their notes in reference to protecting livestock (see below) and avoiding displacement to such protected areas (see above).

New Forest Dog Walkers Code:

  • Throughout the year, avoid disturbing coastal birds by exercising your dogs away from them.

None of our proposals about the use of leads are blanket applications of the sort the Kennel Club would say unduly restrict exercise.  However, how well they fit all the PSPO criteria may need further discussion.

 

Out of control dogs worrying/chasing/attacking livestock.

Kennel Club Guidance:
Displacement occurs when restrictive measures result in dog walkers moving to other pieces of land, resulting in the creation of new conflicts. For example, a local authority may introduce measures excluding dogs from a particular area – like a local park or playing fields – which could subsequently result in dog walkers finding an alternative yet unsuitable location, such as a field with grazing livestock. It is important that councils consider the suitability of alternative sites when imposing restrictions in order to prevent displacement from occurring.New Forest Dog Walkers Code:

  • Do not allow your dog to chase or attack livestock, deer or any other wildlife.
  • Keep your distance from grazing animals, especially mothers and their young.
  • Keep well away from any work taking place such as forestry and pony round-ups, and observe warning signage.

While most existing codes of conduct find these behaviours unacceptable, the law, in the main, applies to the rights of the landowner to protect their livestock.  A notion complicated on the common, open access lands of the New Forest.  Ironically, NFDC’s evidence for their PSPO to stop the public from feeding and petting Forest livestock, included a report by Dr. Jo Ivey that showed a third of 2018 incidents reported to Verderers were of dogs attacking livestock[◊].

 

Persistent dog fouling of car parks and paths.

Kennel Club Guidance:
Dog fouling measures promote responsible dog ownership by requiring that dog owners pick up after their dogs wherever they are, which could include fields and woods in the wider countryside. Following these orders are vital. In areas where farm animal graze, for example, dog fouling measures should be strictly followed in order to reduce the risk of passing Neospora and Sarcocystosis to cattle and sheep respectively.Having the ‘means to pick up’ means that dog owners, when directed by an authorised officer of the council, must be able to produce a waste bag or other suitable means for removing dog faeces and transporting it to a bin. Responsible dog owners will usually have dog waste bags or other devices to clear up after their pets, so following this order shouldn’t be a problem.
New Forest Dog Walkers Code:

  • Pick up after your dog; put bagged dog poo in a dog waste bin or litter bin, or take it home.

The Kennel Club expresses unequivocal support for failure to pick up, despite previous concerns expressed in their 2016 document, they now accept “means to pick up” orders.  Although we would naturally want to advance a more stringent version of the order, for protection of habitat and livestock, our suggestion follows the guidance for PSPOs which unfortunately excludes these factors, but is concerned with persistent nuisance in the public space, which, at the very least includes paths and car parks.  We may find other stakeholders amenable to a wider version of this, but this minimum start point is a way forward that would be difficult to oppose.


Leaving bagged faeces (Littering).
For some incomprehensible reason there is a subset of dog walkers who fully accept and follow the guidance to pick up and bag their dog’s faeces, but are blithe to the obvious requirement to dispose of the bags responsibly.  Whether you’d rationalize it as unintentional littering, or left in a spot they mean to return to so as not to bear the burden throughout their walk, it is unacceptable laziness.  Leaving the bags behind alone is a hazard for wildlife and livestock on the Forest, leaving poo bagged creates a toxic timebomb, a petri dish for growth of the bacterial nasties in the poo.  Whether this should be part of a Littering or Dog Control PSPO, it merits a circle in Dante, and in some quarters already has campaigns targeting just this behaviour.

What Have We Left Out?
Many existing Dog Control PSPOs have limitations on the numbers of dogs per walker, usually between four and six (inclusive, for the pedants shouting “five”).  We would support such a limitation, if Forest stakeholders would agree.  The question may be difficult to address fairly: some owners seem to be unable to adequately control one dog off lead, where others may be able to marshal eight effectively.  The expected argument being : should some be disadvantaged by the weaker links?

Oddly enough, the Kennel Club’s current guidance doesn’t address this at all, nor their earlier 2016 assessment, which mentions per walker numbers in passing as one of the features of the DCOs preceding PSPO.  The Kennel Club did praise a change to  Wyre Forest’s Dog Control PSPO which increased their limit from three to six, characterizing the original as an unfair blanket restriction. [**]  Though the notion was under discussion in the formulation of the New Forest Dog Walkers Code, no agreed restriction survived the final draft.  The Professional Dog Walkers’ Charter [] includes a maximum of six dogs per walker.  We were unable to endorse this charter primarily as it does not address the commercial use of the Crown Lands done outside the standard permission system, but also because we felt that six is not a realistic number for one person to adequately control off lead dogs on the Forest.

For both the dog fouling and leads requirements some PSPOs also include a stipulation to show that walkers are in possession of the equipment necessary to follow restrictions; for instance, specifying having the “means to pick up”, as their lack is tantamount to an intention to ignore the responsibility imposed by the order.  However, including a power for authorised persons under the order to ask members of the public to produce their leads and poo bags as proof of compliance, may not square with the more education based and light touch enforcement which seems to be the current intention.  These may only bear inclusion if requested by all Forest stakeholders, the authorities tasked with enforcement and New Forest District Council.

Hopefully, the other measures we propose, if given consideration and support, might advance the cause of responsible dog ownership in the New Forest, without recourse to more extensive rules.  We look forward to discussion with other Forest groups, we believe these proposals would be a good starting point.  Together we can offer New Forest District Council a sound way forward to a Dog Control PSPO.

In This Series —

Previously:
NFDC Cabinet Advances Prohibitions on Forest Pony Feeding and Barbecues to Consultation

Public Spaces Protection Orders And The New Forest

Dog Public Space Protection Order: A Statement to NFDC Council Cabinet

Protect Heathlands by Restricting Sky Lanterns and Fireworks Along With Barbecues — A Presentment to the Verderers about the Wildfires PSPO

Coming:

 

ENDNOTES:

[*] Richmond Dog control order was partially quashed:
https://www.thekennelclub.org.uk/media-centre/2018/april/victory-for-dog-owners-in-uks-first-successful-pspo-legal-challenge/

https://www.telegraph.co.uk/news/2018/04/13/dogs-can-urinate-lampposts-court-rules/

https://www.richmond.gov.uk/services/parks_and_open_spaces/pspos_and_byelaws

https://www.lag.org.uk/article/205493/challenging-public-spaces-protection-orders

[†] From the Forestry Commission Byelaws:


Acts Prohibited on the Lands of the Commissioners

  1. No person shall in or on the lands of the Commissioners:-

xii. permit any animal in his charge to be out of control;

xiv. permit a dog for which he is responsible to disturb, worry or chase any bird or animal or,  on being requested by an officer of the Commissioners, fail to keep the dog on a leash;

https://www.forestryengland.uk/sites/default/files/documents/Forestry%20Commission_Byelaws.pdf

[ ] Out of Order, 2016, pg 12.

[§] Ibid., Forestry Commission Byelaws

[◊] The Portfolio holder responded to our suggestion of a Dog Control PSPO “It was felt there was not enough evidence at the current time to take this matter forward.  However, it could be considered in the future.  This approach had been accepted by partner organisations.”  One of the evidence documents, cited to support the feeding ponies PSPO, a report by Dr. Jo Ivey collating incidents in 2018 made to either Camping in the Forest staff or to the Verderers Office showed Dogs worrying livestock made up 8% of the CITF incidents, and 33% of Verderers incidents. This included:

  • Camper set dog on a pony: dog got kicked.
  • Shetland foal missing from Lyndhurst Racecourse was discovered 48 hours later in Bartley after having been chased and mauled by dogs, bites to face and body, one ear completely bitten off the other hanging off and was later removed by vet.
  • Foal attacked by dog resulting in foal suffering a broken leg. Foal dispatched by Agister and dog owner told to report incident to the police.
  • {Redacted} other dogs worrying stock, chasing ponies and jumping around cattle laid down. Walker became aggressive after being asked to get his dogs under control.
  • Commoner had a young calf chased by a lurcher. The calf was exhausted and would have been killed by the dog had he not been there the see the dog off. The dog was being walked by a {Redacted} dog walker.
  • Commoner out to remove cow believed involved in incident on 19/7 was unable to get to the cow as she was being circled by two large husky type dogs, owner arrived 15 minutes later and called off the dogs.
  • Dog v donkey. Both animals died.

[**] https://www.thekennelclub.org.uk/media-centre/2021/march/the-kennel-club-welcomes-wyre-forest-district-council-s-decision/

Praise by KC for Wyre Forest increasing number of dogs per walker from 3 to 6, 31 March 2021:

“The maximum number of dogs a person can walk in a controlled manner depends on a number of factors relating to the dog walker and the dogs being walked as well as the location or time of the walk and therefore we don’t believe introducing blanket limits on the number of dogs walked is the best solution. Furthermore, placing a limit on the number of dogs a person can walk risks penalising responsible dog owners simply due to the number of dogs they own, rather than their ability to keep their dogs under control.

“The Kennel Club would recommend local authorities instead use “dogs on lead by direction” orders and targeted measures such as acceptable behaviour contracts and community protection orders to address people who don’t have control of the dogs they are walking.”

[] https://www.newforestnpa.gov.uk/app/uploads/2020/03/New-Forest-Professional-Dog-Walkers-Charter.pdf

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Public Spaces Protection Orders And The New Forest

New Forest District Council has sent two draft Public Spaces Protection Orders (PSPO) , which we broadly support, for public consultation.  The first to ban the lighting of fires and use of BBQs (principally on the Crown Lands), and the second to ban the feeding and petting of ponies, horses, mules, and donkeys in the open areas of the New Forest.  The consultation runs for nearly 8 weeks from  Monday 6th December 2022 to Friday 27th January 2023.

In this second in the series on PSPO’s we explain what they can (and can’t) do for the New Forest.

What are PSPO’s and what can they do for the Forest?

Public Spaces Protection Orders prohibit anti-social behaviours or require certain restrictions on activities within a given public space.  This allows councils to individually target public nuisances in their area.  Typically targets include alcohol consumption, use of “legal” highs, lighting fires or BBQs.  More unusual orders involve intentional feeding of gulls, busking, flying drones, dangerous cycling/skateboarding, and releasing balloons.  The most common type of PSPO across all councils are for dog control; primarily dog fouling, but also conditional lead requirements and exclusion zones (usually sports ground and children’s play areas).

This may sound like councils are given free reign to attack any bugbear of the local populace, however the council must produce evidence that the target behaviour is detrimental to those in the locality, is persistent, is unreasonable, and justifies restrictions imposed under the order.  Guidance suggests that councils look for other ways to address each issue, in some instances existing laws or voluntary codes of conduct or other initiatives may achieve sufficient compliance with rules.  PSPOs should be used responsibly and proportionately in response to issues that cause anti-social behaviour and where necessary to protect the public.

As a minimum, each PSPO must set out:

  • what the detrimental activities are
  • what is being prohibited and/or required, including any exemptions
  • the area covered
  • the consequences for breach
  • the period for which it has effect.

Consequences are usually the imposition of fixed penalty notices (varying between £50-150, frequently £100).  A PSPO can last for up to three years, after which it must be reviewed. If the review supports an extension and other requirements are satisfied, it may be extended for up to a further three years. There is no limit on the number of times an Order may be reviewed and renewed.  PSPOs may be subject to legal challenge, poorly worded or shoddily evidenced orders have been successfully challenged.[i]

To give an example of how a PSPO may work in practice:  a 2015 PSPO from North East Derbyshire District Council reportedly banned golf equipment from an area of a park.  As noted, each PSPO only operates within a defined public space within a council area.  The area was “the open park areas at and surrounding the Hut and BMX track” in Mickley.   Evidently the public nuisance was caused by golfers practicing in an area unsafe for users of the adjacent BMX track.  The PSPO was not extended beyond its first three year term, so ostensibly the temporary ban effectively reduced, eliminated, or changed the target behaviour.

While more perennial behaviours may not be so easily altered, the built in three year maximum forces a review before any extension.  A 2015 PSPO which rightfully targeted hooliganism in Salford Quays: jumping from bridges, throwing wheelie bins or animals into the water, interfering with lifesaving equipment, also included a widely derided ban on “foul and abusive language”.   Free speech advocates challenged this, and this clause was dropped from subsequent versions, without recourse to a judicial review.

PSPOs and The Forest

PSPOs were established within the Anti-Social Behaviour Crime and Policing Act 2014.  Although the powers have existed for eight years, the two NFDC orders going forward to consultation are the first that this District Council have proposed.  It is apparent that they have wisely waited to benefit from the experiences of implementations elsewhere in the country, and to gather supporting evidence for their proposals.

Over the past few years the Park Authority, Forestry England, Verderers, Recreation Management Strategy and other key Forest groups have discussed with NFDC the possibility that PSPOs might address a range of issues on the Crown Lands including:

  • Parking on verges
  • Wild camping
  • Wild fires and BBQs
  • Out of control dogs
  • Feeding and petting of animals
  • Cycling off the permitted network

However, some of these don’t easily fit PSPO criteria.  Parking on verges is primarily an environmental issue for its material damage to the SSSI.   Establishing that it is necessary to protect the public is limited to instances where verge parking blocks gateways for emergency vehicles.  Both wild camping and off network cycling have a similarly tenuous case under PSPO criteria, and are already addressed under existing byelaws.

Verge Restoration Before / After

The two issues, wildfires and BBQs, and the feeding and petting of livestock, NFDC have now moved forward fit the criteria.   Wildfires are an obvious danger to the public, the subsequent devastation may also be viewed as detrimental to public enjoyment.  Feeding and/or petting of Forest livestock for all of its ill effects on the animals and their owners, also causes behaviours in the animals that make them a danger to the public.   When inappropriately fed, semi-feral animals or those protecting their young may become aggressive, and some animals will loiter more frequently and dangerously near roads.  These problems are well evidenced as may be seen in the documents available in the consultation.

When we suggested that the Council should also move forward with a dog control PSPO, they demurred “It was felt there was not enough evidence at the current time to take this matter forward.  However, it could be considered in the future.”  Ironically one of the evidence documents, cited to support the feeding ponies PSPO, detailing incidents in 2018, showed “Dogs worrying livestock” made up 33% of incidents reported to the Verderers.  So while that issue is off the table for now, the upside is that all Forest stakeholders, including dog owners, have an opportunity to help craft an order consistent with the already agreed upon code of conduct.

Education and Enforcement

PSPOs confer a duty on the authority to provide adequate signage to indicate where they are in effect.  Signage in the Forest has always been a tug of war between positive education and minimizing urban clutter in our idyllic landscape.  No doubt this will be another tricky series of discussions.  One of the reasons we’d hoped to add a Dog Control PSPO to this round of consultation was to save the effort and expense of reinventing that inevitable wheel.

Enforcement will be through fixed penalty notices issued by authorised personnel, representatives of the council or another nominated authority.  From the minutes of the NFDC Cabinet meeting:

It was reported that there had been discussion with the National Park Authority, Verderers and Forestry England and it had been accepted in principle that they would play a lead role in the enforcement of the PSPO activities, should they be introduced.

So it is likely, but still to be determined, that this will fall to the Rangers of both the National Park and Forestry England, potentially other staff.  There will be training and resource issues for any of the organizations that come forward.

At the November 2nd Cabinet meeting, in response to a query whether the PSPO should include the touching and petting of ponies, supposing the feeding was the strongest factor for behavioural change, Council Leader Edward Heron, after defending the inclusion of all these actions, characterized a balanced view for enforcement:

The idea is not to be lurking in the bushes with your book of tickets to leap out. The answer is, the ability is there if you are in one of the car parks, if you are talking about one of the Forestry England Rangers or one of the National Park Rangers talking to people. And there is someone walking into a herd of ponies and petting and stroking them.  And they tell them not to, and explain why.  And then asked them more firmly not to, and explain why, and the fact that they are perhaps taking their children in and risking them doing this. Yes. At some point, should they consider it appropriate and proportionate to do so, I want them to have the option to issue this penalty. Again. I really hope.  I don’t think anyone wants this to be a place where we’re out issuing penalties. Everyone wants this to be a place where everyone can enjoy the Forest, whether they live here, work here, visit here in a way that’s responsible, in a way that preserves it, in a way that keeps them all safe.

Public Spaces Protection Orders are not going to be an all singing, all dancing solution to the ills of the Forest.   However, they will be a tool, which used sensibly may raise the profile of the issues they address, give bite to those education messages and promise consequences for those who feel all too entitled to ignore them.

In This Series —

Previously:
NFDC Cabinet Advances Prohibitions on Forest Pony Feeding and Barbecues to Consultation

Subsequently:

Dog Public Spaces Protection Order: A Statement to NFDC Council Cabinet

Protect Heathlands by Restricting Sky Lanterns and Fireworks Along With Barbecues — A Presentment to the Verderers about the Wildfires PSPO

Coming:

PSPOs for the Dog Control in the Forest: Our Recommendations For a Draft Dog Control PSPO, how they stack up against existing guidance, and What the Kennel Club Says About PSPOs

ENDNOTES

[i] Richmond Dog control order was partially quashed:
https://www.thekennelclub.org.uk/media-centre/2018/april/victory-for-dog-owners-in-uks-first-successful-pspo-legal-challenge/
https://www.telegraph.co.uk/news/2018/04/13/dogs-can-urinate-lampposts-court-rules/

https://www.lag.org.uk/article/205493/challenging-public-spaces-protection-orders

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