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GETTING INVOLVED IN PLANNING: ANALYSIS OF CONSULTATION RESPONSES

CHAPTER FOUR: INVOLVEMENT IN DEVELOPMENT PLANNING

INTRODUCTION

4.1 Questions 2 - 5 in the consultation document were concerned with involvement in various aspects of the development plan process. A number of proposals in respect of greater public involvement in strategic planning had been flagged in the Review of Strategic Planning document - in particular: more site specific proposals; a biennial stocktaking exercise (Action Plan) and public examination of objections. Consequently, the focus of inquiry in this section of the Getting Involved in Planning consultation was primarily with possible changes to Local Plan procedures.

NOTIFYING PEOPLE ABOUT CHANGES TO DEVELOPMENT PLANS

4.2 The Executive has indicated that it is a longstanding objective to involve people much earlier in the planning process, and that in this context, councils have traditionally consulted widely on development plans. However, notwithstanding this activity, there were still concerns as to whether people properly understood the extent to which they might be affected by new proposals. Consequently, Question 2 in the consultation document put forward the new possibility of direct notification of groups in the population who may be directly affected by proposed changes in the development plan.

Question 2: Where people are going to be directly affected by policy changes in a development plan, we think direct notification of owners, tenants and neighbours should be considered. Do you agree?

The Executive indicated that neighbour notification already takes place for planning applications and suggested that it could be extended to development plans. However, it was recognised that this would be costly and hence it should be for councils to choose whether to adopt the procedure and not be a requirement in every case.

4.3 Table 4.1 shows the breakdown of responses to this question for each of the main stakeholder groupings. Overall 78% of respondents supported the proposal with 11% expressing clear opposition. The 11% giving a "mixed" response either did not have a strong view on the matter or, while supporting the proposal in principle, heavily qualified this in terms of the practicalities of implementation. There were relatively clear divisions between stakeholder groups on this question. Support was strongest amongst the public and the voluntary sector. Local authorities were generally against the proposal, with only 17% expressing clear support and the remainder having varying degrees of concern. Businesses also did not generally support the proposed notification arrangements. Professional and Academic respondents had relatively mixed views, although the actual numbers involved were quite small.

Table 4.1 Views on the notification of planning policy changes

Note: The overall response rate for this question was 86%

4.4 The large volume of support for the proposal amongst the voluntary sector and individual respondents was based on a number of factors. There was a strong view that the present arrangements often failed, and people and groups found out too late in the planning process that something was happening. As one individual commented,

"The current policy of stuffing copies (of the plan ) in local libraries and expecting busy people to make the effort to review them has to be rethought."

The view that more direct information about potential changes was a good thing in itself, in terms of transparency and accountability was also a recurrent theme. A few respondents thought that it may make decision-making quicker if there was earlier understanding of the issues and one private individual felt that it would, "certainly draw more people into the process". Most of these comments were made in the knowledge that there may be significant logistical and resource implications in carrying out the notification.

4.5 A number of common queries and comments arose regardless of whether respondents were for, against or uncertain about the proposal. Many of these were concerned about the practicalities of the process. Who should be notified? What type of changes should trigger notification? When should it take place? Should it be discretionary? What would it cost?

4.6 Many local authorities and a significant number of other respondents raised concerns about who might have a notifiable interest in development plan changes, although this was obviously linked with the issue of what type of changes might trigger notification. As one local authority put it,

"For many planning policies it would be difficult to identify those people who would be directly affected and decisions would become open to challenge by any excluded person. As such the proposal is discriminatory and unworkable."

This difficulty was also highlighted by a private individual respondee who posed the question,

"…how do you determine who are 'directly affected'? A set of 'rules' should be drawn up…I suspect this will be quite a challenge once you go beyond the obvious."

4.7 There were concerns that for some policies the whole population of the area would need to be notified and even linear proposals, like transport routes, would have a substantial notification requirement. A number of respondents also highlighted the significant property information requirements, which would be necessary to underpin the exercise and doubted that current databases were adequate for the task. Consequently, the threat of legal challenge due to failure to properly notify interested parties was seen as very real by local authorities. On the other hand, those in favour of notification wanted it extended to include community councils and other relevant community groups, and there were also suggestions that it should include everyone in the area of the plan or potential users of the planned developments. A business respondent considered that the Executive should maintain a statutory list of groups to be consulted in relation to development plan proposals.

4.8 Concerns regarding the logistics of identifying those affected by the plan led to suggestions that notification should be limited to site specific proposals. There were suggestions that these should be restricted to developments above a certain size, although this was not defined. It was also pointed out that this raised matters addressed in the Review of Strategic Planning for new strategic development plans to be site specific in certain respects. It was also suggested that notification be limited to developments requiring an Environmental Impact Assessment (EIA), those with bad neighbour type connotations and where, " significant change was under consideration". A majority of local authorities who were not wholly opposed to the proposal, supported some form of limited site specific notification, so long as there were clearly prescribed criteria.

4.9 The question of at what stage in the plan-making process notification should occur was raised by a few consultees. Two authorities had carried it out at the consultative draft stage, although there were suggestions in response to Question 5 that this stage could be omitted in the interests of speeding up the plan adoption process. One private individual took the view that,

"These notices should be served at the appropriate point in the preparation of a development plan - draft, finalised and modification stages - when the proposals first appear, in order to draw owners' attention to the implications for their land."

4.10 The proposal that notification should be discretionary attracted a good deal of comment across all stakeholder groups. Most of the submissions took the view that it if this were to be introduced it would be need to be on a consistent basis across Scotland. Voluntary sector and public respondents tended to emphasise the need for the procedure to be mandatory and not just for authorities to 'consider'. Again there were calls for further guidance to be produced, possibly in the form of a Planning Advice Note, on what was expected by the Executive.

4.11 There was near universal comment that the proposal would require resources and be time-consuming. Many local authorities stated that they would need additional resources if they were required to implement the proposal and one regretted that the consultation document had not highlighted this as it had done with the neighbour notification of planning applications. Many business and professional interests were concerned on this account and as one development industry respondent put it,

"This would be very costly and could make a cumbersome local plan procedure even worse."

And that this,

"…will add to the time/resource requirements of planning authorities at a time when resources are already stretched. (Planning Consultant)

The logistical and resource problems outlined above were considered by some consultees opposed to the proposal as clearly working against the Executive's objective of achieving a speedier delivery of plans.

4.12 Given some of these difficulties, many respondents queried whether the proposal was cost effective and suggested alternative ways of improving the development plan consultative process. There was agreement that statutory notices were not particularly effective, but there was a need to think more imaginatively about other means of engagement. Some thought that Action Plans and Local Planning Policy Forums would help. Others suggested greater and wider use of different media - websites, newsletters, site notices etc. - as well as better availability of plan documents at a reasonable cost. Some community councils thought that they could play a more active role in the development plan preparation process as an expansion of their role in development control. There were also several calls for best practice advice on involvement in development plans to be issued by the Development Department.

LOCAL PLAN INQUIRY AND ADOPTION

4.13 Questions 3 - 5 were concerned with a number of existing local plan inquiry and adoption procedures. The Executive's proposals in respect of Reporters were intended to strengthen their independence and thereby increase public confidence in the system. Comments were invited on how to improve the local plan adoption process.

Question 3: We think Reporters for Local Plan Inquiries should be appointed independently by the Scottish Executive Inquiry Reporters Unit, who would conduct the Inquiry and recover costs from the council. Do you agree?

Currently local plan inquiries are the responsibility of the planning authorities who bear the cost of conducting them. They choose a Reporter from a list provided by SEIRU. The Executive's proposal would remove this discretion with SEIRU making the decision on each appointment.

4.14 Table 4.2 shows the breakdown of responses to this question for each of the main stakeholder groupings. Overall 87% of respondents supported the proposal with only 8% expressing clear opposition. The "mixed" response to this question consisted almost entirely of "don't knows" and "no comment". There was a high degree of unanimity amongst all stakeholder groups in relation to this question, with support varying between 100% from professional and academic respondents to 75% of the public body responses, although again the actual numbers were quite small in both of these instances (10 and 8 respectively).

Table 4.2 Views on the appointment of Reporters by SEIRU

Note: The overall response rate for this question was 84%

4.15 Those supporting the proposal felt that it would help strengthen public confidence and remove any perception of bias or collusion between the local authority and the Reporter. Many thought that it would be a more open and transparent approach and be seen as fairer than the current arrangements. A number of respondents also drew attention to the provisions of the Human Rights Act and the possibility of challenge to the independence of the Reporter under current arrangements

4.16 However, there was little support, across all respondee groups, for the suggestion that costs would continue to be recovered from local authorities. A number of local authorities pointed out that the cost of Inquiries was usually high and unpredictable causing difficulties for budget setting, especially as expenditure was effectively controlled by a third party. A professional body made the point that,

" The cost and complexity of modern large scale Inquiries is way beyond the ability of the average local authority budget."

4.17 The most prevalent view on funding Inquiries was that the Executive should bear the cost although there were several submissions that considered that a scheme based on sharing costs should be devised. For instance if the Inquiry was subject to unjustified delay by the actions of a local authority more of the cost burden could be borne by them, or the cost of preparing the Reporters report could be shared. It was suggested that the Reporter could be empowered to seek costs arising from frivolous or vexatious objections, or where abortive work had been carried out. There was also a view that developers should contribute to general Inquiry costs.

4.18 A number of local authorities saw advantages in the proposal if some or all of the administrative responsibilities for Inquiries were transferred to the Reporters Unit. This included the suggestion that SEIRU might provide the Programme Officers for the Public Local Inquiry.

4.19 Parties opposed to the proposed change cited the Reporters professionalism, the need for local knowledge and continuity of approach. Some were concerned about centralisation and the loss of local accountability for decision-making and others felt that a SEIRU appointment would not necessarily increase public confidence. At its most extreme, one community council considered that the Reporter system should be replaced entirely as they had no local knowledge and did not have to live with the consequences of their decisions. The local authority view should prevail unless it was "unreasonable".

4.20 Other related suggestions were made regarding Reporters. These included the need to improve their training (disability awareness was particularly mentioned by some respondents), and to broaden selection from those with local authority backgrounds. Two respondents suggested that there should be a Panel of (possibly 3) Reporters at Inquiries, which would again provide wider expertise. One professional body urged the Executive to give consideration to extending the powers of Reporters to cover other inquiry procedures such as relevance of representations, control of witnesses and cross-examination. There was also a view that Reporters should be required to declare whether they are Freemasons.

Question 4: We think the scope to depart from the Reporter's recommendations should be limited. Do you agree?

Currently planning authorities are not bound to accept the Reporters recommendations before adopting the plan though if they take a different view they must publish their reasons. These aspects of the arrangement have been criticised, and some research has argued that the recommendations should be binding. The Executive therefore proposes that discretion to depart from the recommendations should be limited. Local plans would be automatically adopted within a set time, in line with the Reporters report unless the local authority advises all parties that it seeks to depart from the recommendations and gives them 21 days to respond. If the authority still seeks to depart from the Reporters recommendations it would then require to obtain the permission of the Scottish Ministers. Each plan would also be required to obtain a certificate of conformity with national policy.

4.21 Table 4.3 shows the breakdown of responses to this question for each of the main stakeholder groupings. Overall 79% of respondents supported the proposal with only 14% expressing clear opposition. The "mixed" response to this question consisted of many "don't knows" and "no comments", although there was also a small number of positive but heavily qualified responses and others seeking further information. There was a high level of support amongst all stakeholder groups to this proposal, with the exception of local authorities. Support varied between 94% amongst the business community to 78% from professional and academic respondents. Only 48% of local authorities clearly supported the proposal while the balance of their responses indicated varying degrees of reservation.

4.22 The overwhelming majority (83%) of all the "yes" respondents came from the public and voluntary sectors and the principal reason cited for support was that without such an approach it was felt that the Public Inquiry process was a waste of time and that current procedures engender mistrust and disillusionment. A typical comment from this group included,

"Participation in a PLI is an exhausting and time consuming process. If the Reporter's recommendations are set aside then justice has not been seen to be done" (Private Individual)

Table 4.3 Views on whether Reporters recommendations should be more binding

Note: The overall response rate for this question was 84%

4.23 Other reasons given in support of the proposal were that it would promote greater confidence in the objectivity and impartiality of the Inquiry and might, therefore encourage more people to get involved. Some also thought that the proposal would speed up the approval process possibly by between a third and a half by eliminating the modifications stage. It was also felt that this might encourage all parties to negotiate outstanding objections. A number of local authorities thought that public perceptions of the process would be improved as councils would no longer be seen as 'judge and jury' in respect of the plan.

4.24 The key concern, across all stakeholder groups, was the degree of flexibility to depart from Reporter's recommendations which would be retained by the new proposal. Specifically, some respondents suggested that there was a need for:

• Ministerial approval to act as a reasonable safe guard
• local authorities to set out their case for departure and subject that to stakeholder comment
• advice from the Executive to clarify the criteria/parameters by which departure applications might be judged

4.25 Three main reasons were cited in opposition. First, that Reporters are fallible and will get things wrong from time to time, or that circumstances can change and there needs to be a reasonable amount of flexibility to cope with these events. Second, that the scope for departure is limited enough at the moment (and could be further proscribed by the need to obtain a certificate of conformity from Ministers), Reporter recommendations are not, in general, lightly set aside and there remains the option of legal challenge in some circumstances. Third, and this was mainly mentioned by local authorities, there was a view that the proposal would represent, ".. a very serious dilution of democratic accountability…" and would, ".. introduce elements of doubt about the 'ownership' of the local plan…".

4.26 A number of alternative or additional suggestions about local plan adoption and the role of Reporters were also made. One individual planner suggested that where new matters come to light an expedited procedure for re-opening local plan inquiries might be considered and that local authorities might also be allowed to adopt development plans in part where objections still needed to be resolved. Another individual response felt that the Reporter should be able to consult a range of experts before finalising his/her report and recommendations. There were also many submissions from the public and local voluntary bodies complaining that community views were not adequately taken into account in Local Inquiries.

Question 5: How can we make local plan adoption faster and more user-friendly?

Even with suggested changes local plan adoption will still be time-consuming and difficult for people to understand. We see no easy answers. In the longer term there may be opportunities for the exchange of information and debate on the internet. These could open up the early stages of plan preparation and review, speed up the handling of objections and cut the time required for public sittings. Mediation may also have a role in dealing with objections.

4.27 This was an open question to which there were 258 responses, with stakeholder representations broadly in proportion to their share of overall responses. There was a significant number of responses which were concerned that this issue merited specific in-depth research and a comprehensive review in its own right and not just as part of the present exercise. One respondent regretted, given the importance of the issue, that the Executive had not put forward positive proposals itself, but had merely invited comments.

4.28 Many respondees agreed that this was a very difficult issue, while a proportion of these, which included significant community representation, felt that it was not possible to reconcile a faster and more inclusive process and queried why speed was important. As several respondents remarked, "It is more important to get the plan right than to get it quicker." (Local Community Group)

A number of the responses also advanced the view that, collectively, the proposals in the present consultation exercise would have the effect of slowing the process down.

4.29 Generally, however, respondents suggested factors that they considered would be helpful in improving current procedures. A wide range of comments were submitted and they broadly fell into seven major categories. These were:

• Stages in the local plan process
• Form and Content of local plans
• Publicity and Consultation processes
• Project management
• Use of Technology
• Staff Resources
• Public Local Inquiry (PLI) Procedures.

4.30 Observations querying the need for all the present stages in local plan preparation came from all stakeholder groups, but were particularly strong amongst local authorities and other professional/business interests. Most of the focus in this context was on abolishing the Consultative Draft stage of the process and ensuring that there was more effective engagement with stakeholders in the remaining stages or focused on the most meaningful point in the process. However, many supporters of this approach recognised that it could be perceived as reducing the opportunities for involvement. As one council put it,

"The most radical suggestion would be to reduce the number of consultation stages in the production of the local plan…..Reducing the stages might shorten the process but may also alienate the public who might feel that opportunities for meaningful consultation had been reduced."

A few community organisations specifically indicated that they did not support the removal of the Consultative Draft stage, while others thought it might make the system easier to understand. Some business/professional respondents made the different point that local authorities were too committed to Draft Plans and they should be more open to other options being brought forward. This would not necessarily speed up the process but might improve "buy in" which may be advantageous at a later stage

4.31 The other major area of concern was with the post-Inquiry Modifications stage where there were considered to be onerous notification requirements and opportunities for streamlining procedures. However, it was recognised that the proposals to strengthen the status of the Reporters Report and the associated departure procedures set out under Question 4 would potentially improve this stage of the process. There was also the suggestion that authorities should be enabled to partially adopt a local plan where significant, unresolved objections were holding the process up.

4.32 Changing the form and content of local plans was seen as potentially having benefits not only for faster completion but also for increased user-friendliness. A number of community respondents complained that some existing local plans were, " huge and overcomplicated". There was, however, widespread support across all respondee groups, for change which encompassed the following range of suggestions:

• Shorter , more realistic plans focussing on key issues
• Wider use of model or standard policies
• Clearer statements on the implications for individual communities
• Use of simple, jargon free language
• Better presentation within the document
• Wide distribution of concise, easy-read versions.

4.33 One local authority thought there should be only one local plan per authority area and a commitment to 2 yearly reviews. Another respondent suggested updating settlement components on a rolling basis rather than full reviews. Some of these ideas were suggested in the Review of Strategic Planning and others have already been adopted by individual planning authorities. There were several suggestions that some form of Good Practice Guide or revised Planning Advice Note might be appropriate.

4.34 Improved consultation, publicity and capacity building were seen as key components of improved user-friendliness, some also thought they may also help shorten the process if there was a better and earlier understanding of the issues. Some respondents saw the problem being that involvement often occurs too late and consultation is perceived to be a hurdle rather than an opportunity. In addition, it was felt that,

"There is a need to stress how the local plan directly affects the individual." (Private Individual)

4.35 Early effective engagement with the local community and other stakeholders was seen by many as an essential first step. Some thought this would be more productive if it was focussed.

"It would be appropriate to draw together the key players involved in particular sectors, e.g. housing, at an early stage, to consider and agree the main issues. Drawing in additional interested parties at various stages along the process will encourage debate and negotiation….eliminating significant objections at later stages." (Community Council)

There were related views that focus groups and forums, including the proposed Local Planning Policy Forum would be likely to be helpful in this context, both in raising general awareness as well as responding to specific issues.

4.36 Many public and community representatives felt that current arrangements were not satisfactory and called for earlier, more regular and deeper/broader involvement in the process as well as much better feedback on how views have been taken into account. There was a view from community councils that more could be made of their role - for example, it was suggested that they could be involved in setting up local meetings etc. While traditional approaches may have a place there were views that,

"Workshop-based, facilitated consultation exercises should be regarded as being preferable." (Local Authority)

"Planning for Real sessions have proved to be a useful means of involvement" (Public Body)

4.37 Other respondents thought that there was scope for more training for community representatives and others particularly commended the Planning Aid Scotland CLEAR (Community Local Environment Awareness Raising) Project. Better publicity and information were also cited as areas for improvement, and again a wide variety of media suggestions were made including: press; radio; television; internet; videos; seminars; exhibitions and roadshows. One consultee thought that there should be a requirement for authorities to publish a Scheme for Community Involvement to be approved by Ministers, along similar lines to proposals in the Planning Green paper in England.

4.38 Another recurrent theme from many was the need for better project management of the local plan preparation process. This had a number of facets, but the principal need that was mentioned was for a published management programme, with strict timetables for each stage in the process, published at commencement and kept under review. Some business and professional respondents thought that failure to comply with timetables should involve penalties, while a professional institute considered that if there was slippage local authorities should be required to publish a "Notice of Delay in Plan Preparation". Elements of this approach were flagged up in the consultation document (paragraph 43).

4.39 The possible use of the internet in the local plan process was also highlighted in the consultation document and attracted a reasonable amount of comment. Web-based plans with e-mail links and free CD ROMs were specifically mentioned as well as the ability to download other planning reports from the web, and the use of web-cams to relay Public Inquiry proceedings. However, many also pointed out that internet access is not universal . Views were mixed but on balance supported the contention that it might effectively speed up the process.

4.40 However, contrary to this was the view that it would be mistaken to rely too heavily on the internet, for a variety of reasons. As one community council remarked,

"…many residents do not have ready access to the internet and will feel that a public sitting is more likely to inspire confidence.."

There were also concerns about the confidentiality and authenticity of e-mail correspondence and generally a recognition that new technology would be an addition to, not a replacement for, traditional methods of communication.

4.41 In common with other proposals in the consultation paper, the need for adequate resources was again raised by a significant cross section of respondents. As one national voluntary organisation concluded,

"We understand the constant pressure on the planning system to be both faster and more inclusive. The only obvious means of addressing both with any degree of conviction is to address the issue of resources."

Other respondents commented on the impact of staff shortages on the ability to undertake extensive consultation, engage actively in feed back and negotiate on objections. Some community respondees felt there was a need for a culture change amongst staff with more positive customer care attitudes.

4.42 Much attention focused specifically on Public Local Inquiry (PLI) procedures, with several consultees suggesting that they needed a complete overhaul. There was considerable cross sector support for a less legal and adversarial approach, with some suggestions that QC's and solicitors should be banned from the proceedings and more informal and inquisitorial approaches such as Hearings adopted instead. Some thought that a greater emphasis on written procedures would be helpful. The timing and location of the PLI were also felt to be important factors influencing involvement. Venues near to the community and sittings outside normal working hours were both cited as important in encouraging wider participation. Alternatively, one respondent thought that if the PLI met during normal working hours then public participants should be able to claim loss of earnings.

4.43 There was recognition that the PLI procedures were complex and members of the community would benefit from assistance and guidance on these matters. Several respondents considered that a Programme Officer dedicated to community advice would be useful in this context, while there was also a suggestion that a Legal Aid type of arrangement might be available to provide professional assistance for community representations. Another respondent felt that a Layman's Guide to the whole process would be very helpful.

4.44 Many responses, particularly those from local authorities, felt that there should be a greater focus on trying to resolve objections prior to the PLI and maximising pre-Inquiry agreements. A possible role for mediation in such a process was mentioned by some respondents. Similarly others were concerned with the need to have a better definition of what constituted a competent objection, with greater powers to reject vexatious, frivolous or time-wasting objections. A more radical proposal was that if there were to be public examinations of strategic plans, which might include some site specific issues, then there was no need for a local plan PLI at all.

4.45 Several respondents produced a checklist of factors which they considered "best practice" in the running of an Inquiry. These included the following suggestions:

• Rigorous timetabling of the proceedings
• Use of appropriate IT software
• Sitting 9am - 5pm (and later for the community)
• Use of common document formats
• Preparation of topic/issue papers
• No reading of precognitions
• Time limits for the discussion of objections
• Use of two Reporters
• Use of a panel of planning witnesses
• Emphasis on customer care.

4.46 Overall, there was a general consensus on the need to change the present system of local plan preparation and adoption, however, views were varied as to whether this required a radical review, or whether the basic framework was sound but some modifications to key processes and procedures could deliver the required improvements for greater speed and inclusiveness.

OTHER RELATED DEVELOPMENT PLAN MATTERS RAISED IN RESPONSES

4.47 A number of responses from community groups and joint committees drew attention to the fact that they considered that public involvement in structure plans was also relevant to the consultation exercise. As one consultee put it,

"… there is a clear desire for greater participation (in structure plans) but there is an endemic challenge in terms of the logistics of the process, the relative role of key agencies and the form of the plan being non site specific."

While, effective participation at a strategic level was generally considered to be difficult, the same respondent who had been involved in a structure plan consultation exercise considered that communities and individuals had been able to grasp the strategic planning issues.

4.48 Another private individual respondent considered that the present development plan system was too flexible, leading to an excessive dependence upon development control. They suggested that,

"A more prescriptive, legally based document would reduce the scope for variation; decision would be more automatic and need less professional input. It would also give the public more idea of how their environment was going to be planned….and give confidence to the public that their participation in the development plan process would have a meaningful outcome in terms of subsequent decisions."

4.49 He suggested that other benefits could flow from this approach. There would be more incentive for planning authorities to review and alter their plans on a regular basis because out of date plans would remove their development control powers. Refusal of consent would be based more on the provisions of the plan, and alterations would become the normal way of adapting plans to interim changes of circumstances. Third party appeals, could be introduced but would only be activated when an authority proposed to approve development, which was a departure from the development plan. It was suggested that both developers and members of the public would benefit from this approach since they would have a greater certainty of knowing the likely outcome of a planning application.

4.50 The need for a more deterministic approach to the development plan was also suggested by a small cluster of responses from community groups and individuals, all of whom were concerned about the uncertainty which the present system imposes. As one local voluntary organisation commented,

"We think that once the Local Plan is in place, it should be sacrosanct for the period of the plan. Too often developers come forward with a proposal which is in direct contravention of the plan within months of a new plan being put in place."

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