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New PAN on Community Engagement
Local Authorities
Argyll & Bute Council: The Executive seems to assume that Development Plans do not yet fully engage with local communities at an early stage in the process. This is not the case for the vast majority of Scotland's Planning Authorities where every effort is made to find out the views of the public. The Executive must be made aware that effective community engagement is a time consuming process that can give rise to serious challenges in the preparation of development plans Better guidance is also required on what is, or not, an acceptable objection as the use of multiple pro-formas is on the increase adding considerably to workloads.
Dundee City Council: The Council recommends that the proposed PAN be issued in draft for consultation as its content will have fundamental implications for public participation in various aspects of the planning process.
East Renfrewshire Council: This will be awaited with interest. The challenge that effective engagement poses cannot be underestimated. Despite the best efforts of many Planning Authorities, East Renfrewshire included, to involve more local people this does not seem to have made much difference, due largely to a general apathy towards planning matters unless it is a proposal that directly affects them. Furthermore, there is an obvious tension between more effective engagement and efficiency in the Planning system.
Glasgow City Council: The Scottish Executive envisages the new PAN as being the authoritative guide to community engagement on planning. This will have the advantage of clearly setting out what may be required from the Council by way of public involvement in the planning system. There may be resource implications relating to the implementation of the detail of the PAN. These will become clearer on publication.
Moray Council: Support in principle but welcome further guidance in terms of public involvement. This would be most beneficial if produced as a national model with guidance on different types of scenarios.
North Lanarkshire Council: The Council will be pleased to be involved in any consultations on the PAN on Community Engagement.
Shetland Islands Council's (interim response): Our main concern in reviewing this section of the White Paper is that there appears to be no attempt to set the discussion in the context of Community Planning, which as you will be aware, has a significant bearing on the way in which local authorities now approach issues involving public consultation. We think there is scope to undertake consultation in a more joined-up manner than has sometimes been the case in the past. We believe that this would help to reduce the scope for confusion between community planning and local development planning. Identifying the scope of each would be of great assistance and we believe that that should be reflected in guidance and, if appropriate, in legislation.
South Lanarkshire Council: There are no objections, in principle, to the proposals set out in the White Paper, however there can often be differing views on what constitutes 'effective community engagement'. As such this could be a source of dispute between developers and the community with the Council seeking to arbitrate. Such a situation could divert resources in actually producing development plans and processing planning applications thereby impacting on other priorities that the White Paper seeks to support. Therefore, the forthcoming guidance will require to be clear and, importantly, have the support of the development industry, Councils and other interested parties.
Non Departmental Public Bodies
Disability Rights Commission ( DRC): We support the introduction of a Planning Advice Note on Community Engagement that should help planning authorities engage effectively with different stakeholders and community groups. However, we feel that the guidance should take account of the needs of different groups to ensure effective participation at the appropriate level. In particular, the guidance should detail the methods of involving disabled people in the planning process e.g. the provision of communication support or information in alternative formats. The Disability Discrimination Act 2005 will place a Disability Equality Duty ( DED) on public bodies to promote disability equality and eliminate discrimination. If planning guidance takes account of the needs of disabled people to be able to effectively participate, it can assist planning authorities in meeting the requirements of the DED.
Historic Environment Council for Scotland: The historic environment is also well served by many and varied amenity groups often with a localised and specialised knowledge unique to that area. The intention to speed up the planning system, while laudable, will put even further strain on those groups' abilities to respond. Whilst it is already recognised that financial support for training may be required for local authority staff, this may well apply equally to consultees. Consideration should therefore be given to how these bodies might be brought into a more continuous and pro-active role within the system together with commensurate education and a limited degree of funding.
Scottish Enterprise Edinburgh and Lothian: It is noted that there is the intention to collate best practice on community engagement, SEEL are keen to be included as consultees of this process.
Scottish Water: Scottish Water has already signed up to a Consultation Code in respect to our investment programme, and we would welcome involvement in the preparation of the PAN to disseminate the collated best practice approach. This document should define best practice in terms of consultation and will act as the audit document in the planning application determination and appeals processes.
The Development Industry
EDI Group Ltd: The advice to be issued on strengthening the involvement of local people is critically important to making wider inclusion effective. Key aims of the White Paper are to strengthen the involvement of local communities, and to reflect local views better. The introduction of a statutory requirement for pre-application consultations with local people, coupled with the authorities having to assess whether appropriate consultation has taken place, requires sound advice to be issued by the Executive. It is often difficult to reach the local community particularly where opportunities to funnel views through bodies such as the community councils are not taken. Authorities will need to consider how representative these groups are.
Glasgow Harbour Ltd ( GHL): We recognise that many applicants already consult with local people voluntarily in advance of making a planning application. However, in some instances the issue of confidentiality is a key concern for applicants prior to the submission of a planning application. It is possible that an application could be declared invalid if there has been inadequate consultation. Would this be decided by the planning authority? We consider that further details as to how this proposal would proceed are required.
Homes for Scotland: This topic is mentioned throughout the White Paper and in principle Homes for Scotland is willing to work with the underlying spirit and intent. We note, however, that the White Paper does not provide any great detail on the levels of discussion or information to be provided. We look forward to draft guidance being published at an early stage by the Executive for stakeholder input. We are not persuaded that PAN 47 currently provides an adequate basis for achieving this - it states that " discussions on the planning merits of cases between applicants and community councils are strongly discouraged". A key consideration is that community involvement should not unduly delay the processing of the planning application. As an essential stakeholder, Homes for Scotland would be willing to work with the Executive on this matter.
Manor Kingdom Group: Manor Kingdom is willing to work with the underlying intent of achieving greater community involvement. We note, however, that the White Paper does not provide any great detail on the levels of discussion or information to be provided. A key consideration is that community involvement should not unduly delay the processing of the planning application. Manor Kingdom accepts the role the community has in development but is unclear about the level of involvement which society will have.
Muir Group: Guidance requires to be provided on the levels of discussion or information that is to be provided. An important aspect on this matter is that community involvement should not unduly delay the planning process.
Persimmon Homes: The new PAN will have to set out clearly the requirements expected of applicants in the pre-application discussion process. It will also be important to involve developers in the scope of this PAN to identify what will be an achievable consultation strategy based on our past experience.
Stewart Milne Homes: In terms of the proposed greater level of public consultation/participation, early draft guidance should be published at an early stage for stakeholder input. Any participation should not unduly delay the planning process or place additional cost burdens on developers.
Other Businesses
Association of Electricity Producers:AEP welcomes the encouragement of meaningful public involvement in the planning process. It is very interested to find out more about the detail of the proposed community involvement and is keen to be involved in the development of guidance on the matter.
Federation of Small Businesses: We note the development of a new Planning Advice Note on community engagement and would suggest that this considers the value of engagement with business, particularly where applications are likely to impact upon existing businesses.
Institute of Directors: Early thorough consultation is good practice and the guidelines to encourage this will be crucial to success and community involvement.
Orange PCS Ltd: We welcome acknowledgement of the need for greater community involvement in the planning process. Early consultation is important where proposals may be controversial. Orange has already implemented the Ten Commitments to Best Siting Practice with other operators. We would therefore hope that any requirements for additional consultation would focus on LPAs post application work, rather than operators pre-application work. Consultation requirements must therefore be clearly defined and would refer again to the mobile phone operators' model.
Scottish Chambers of Commerce: Detailed guidance requires to be provided on the levels of discussion or information that is to be provided. An important aspect on this matter is that community involvement should not unduly delay the processing of any planning application. The proposals for greater pre-application discussion and consultation are encouraging in this respect.
The Scottish Coal Company Limited ( SCCL): We welcome the preparation of a new Planning Advice Note on community consultation that will set out best practice on engaging in meaningful discussion with the community. However, such guidance needs to recognise that within communities there can often be a disparate range of views and opinions regarding particular development proposals. The guidance should therefore reflect the need to ensure that the broadest possible views of the community are gathered to form a truly representative view.
Universities Superannuation Scheme Ltd ( USS): We recognise that many applicants already consult with local people voluntarily in advance of making a planning application. However, in some instances the issue of confidentiality is a key concern for applicants prior to the submission of a planning application. It is possible that an application could be declared invalid if there has been inadequate consultation. Would this be decided by the planning authority? We consider that further details as to how this proposal would proceed are required.
Professional Organisations
RICS Scotland:RICS Scotland notes the intention to prepare a Planning Advice Note to collate best practice on community engagement and suggest that this Advice Note should be written as quickly as possible so that it is in tune with wider legislation. RICS Scotland supports this initiative, which highlights the need for local people to engage in the Local Plan Review process. We suggest that once best practice is available that land which is allocated in Plans should then have a presumption in favour.
Planning Consultants, Architects and Lawyers
Bell & Scott: When the details relating to this aspect are being drafted it is essential that the Executive takes into consideration the difficulty for applicants in (1) identifying the "community" with whom they are required to consult (2) identifying the true representatives of that community and (3) engaging meaningfully with the community given the lack of interest and involvement which is often apparent from the majority of "community members".
Collar, Neil: As the White Paper itself acknowledges, the public's views are only a material consideration if they raise planning matters. It would be very dangerous to depart from that principle. Public opinion which is a material consideration is taken into account with other relevant considerations. If the views of local people are to be given an elevated status, that will create public expectations of being able to defeat proposed developments. The existing guidance in SPP1 on the relevance of public concern is appropriate and should be maintained.
Drivers Jonas: We recognise that many applicants already consult with local people voluntarily in advance of making a planning application. However, in some instances the issue of confidentiality is a key concern for applicants prior to the submission of a planning application. It is possible that an application could be declared invalid if there has been inadequate consultation. Would this be decided by the planning authority? We consider that further details as to how this proposal would proceed are required.
Academic Bodies and Individuals
Macaulay Land Use Research Institute: Provision of the PAN is commended, but the real barriers to implementing good practice are not the lack of information (plenty exists) but the lack of will, lack of resources and/or lack of time. The analysis of costs (p.50) does not recognise any additional resource burden on the planning authorities through increased public involvement, and suggests that the commitment is either purely rhetorical, or that one of the fundamental tenets of good practice (adequate resources) is not being followed.
Community Councils
Currie Community Council: Stakeholders should include statutorily appointed Community Councils and Local Representative Bodies (such as residential or amenity associations) who may serve similar functions to Community Councils.
Greengairs Community Council and Greengairs Environmental Forum: Our conclusion on what constitutes a community in relation to planning is based on our local situation. There are several villages, hamlets, individual residences and the outskirts of a town all directly located around the perimeter of the main area of opencast and landfill. We would conclude that all of those around the immediate radius of the development should be regarded as the most affected, however the type and size of the development would then dictate how far reaching the impact is likely to be. Anyone who fears that his or her quality of life or financial situation would be considerably adversely affected should be heard. Environmental and heritage organisations need to be included in the process to ensure the effectiveness of protection for the public, environment and natural and cultural heritage. It is our experience that these organisations only get involved when requested by the public. Perhaps the definition of community should be influenced by the fact that we all have a responsibility for the impact that our actions have on others. We are very concerned that local, strategic and national plans could interpret community as the whole country therefore reducing the consideration given to the impacts of developments on those most affected.
Kennoway Community Council: Improved Public Consultation may be addressed in the assurance of enhanced local consultation of Structural Development Plans and Local Development Plans. However, consultation will be flawed if it relies too heavily on website access for information and comment. Opportunities for local viewing and debate are necessary to allow for public participation.
Knightswood North Templar Community Council: this community council supports fully the production of a new Planning Advice Note on community engagement and that compliance with defined criteria on community engagement should become a material consideration in reporters' examination of development plans and individual applications, however, the mere fact of engagement and consultation should not be counted in the developers favour where significant objections remain.
Merchiston Community Council: Planning Advice Notes on collating best practice on community engagement should refer to the potential of Community Councils representing local interests
Milngavie Community Council: Although there are numerous references to 'community groups' and 'local people' there is no mention of Community Councils which have for 30 years had the responsibility to comment on planning applications. Community Councils do have permanent responsibility for commenting on developments over largish communities and over long periods whereas many pressure groups are ad hoc and ephemeral.
Portobello Community Council (and Amenity Society ): What will the proposed Planning Advice Notes ( PANs) on community engagement include and will they be enough to inspire more participation? The paper promises much on increasing public involvement, but will it actually deliver in practice?
Strathblane Community Council: Guidance on community participation is welcomed and we would be pleased to be involved in its preparation.
Voluntary Organisations
Built Environment Forum Scotland: Much is made in the White Paper of making the planning system more inclusive - essentially by front-loading the system. The Issues Report was recognised as a key stage although engagement must be much wider than this. Concern was expressed over the fact that there is little reference to how proposals might be supported through capacity building, to enable the public, and indeed all stakeholders, to engage effectively with the planning process. Equipping people to engage at the right stage in the process will require significant resourcing. The lack of a link into Community Planning and the potential role of community councils were highlighted, as was an enhanced role for Planning Aid. It was noted that much work is required on the practical implementation of notification procedures in relation to Local Plan proposals, to ensure widespread engagement including involvement of the 'silent majority'. All information must be accessible. Widespread engagement is one of the biggest challenges for the planning system.
Colinton Amenity Association: Outwith the context of particular planning cases, arrangements for liaison and information exchange between planning officials and members of the planning committee and local communities should be encouraged to enable community concerns and aspirations to be better understood [by site visits, issues meetings etc]. We strongly support improved opportunities for the meaningful involvement of local people in the planning process. But the sheer volume of consultations and planning applications is in danger of swamping community bodies whose remit is to respond on behalf of their communities. They are staffed mostly by volunteers in retirement, who give their experience and skills freely to support their communities. It is important not to alienate these people and the important contributions that they make by imposing on their goodwill. There is a need to consider how community representative bodies can be better supported to cope effectively with the increased workloads of enhanced participation.
Greenspace Scotland: The key challenge, to deliver on the intent of this paper, will be to ensure that public involvement is meaningful and sufficiently broad to engage a wide cross-section of the community. This must extend beyond traditional written consultations on the basis of a draft plan. The format and mechanisms for involvement will be critical to success and this requires recognition that only a limited number of people are able to understand and visualise plans which are largely text based. There is a need for more innovation and variety in the way that information is both presented and responses are made; not all responses should need to be in writing. Planners will need to develop new skills in community engagement or collaborate with other professions or organisations to do this. The proposed new Planning Advice Note on best practice in involving local people will be critical in supporting a step change in the way people are involved. Whilst guidance is welcomed, it should be acknowledged that meaningful involvement is, and will be, resource intensive; not necessarily in financial terms but in people time. Planning authorities will need to be adequately resourced if they are to achieve the step change in community involvement that is required to deliver the ambition of this White Paper. Across the Greenspace Scotland network, our partnerships have developed substantial expertise in engaging individuals and communities, and in getting beyond the usual suspects. We have also recognised that very often it is only a 'threat' (in the planning context, usually an application or land sale) which engages and motivates the community and so our network has developed some interesting techniques to simulate a 'threat' and the associated response. We would be very happy to share this experience with the Executive, at an appropriate time, to help inform and shape the new PAN.
Helensburgh Study Group: Identifying and rectifying bad practice could be important. Merely setting targets will be insufficient, in our view. We feel that there should be a recognised role for local community groups to monitor performance and a channel for complaints other than to the authority itself. There needs to be something between the current arrangements and the ombudsman. And, of course, there should be a system of limited Community (Second Party) Right of Appeal.
Quarry Traffic Monitoring Group: This is long overdue. The current attitude by planners towards public engagement is one of resentment. 'We know what is best for you' seems to be the prevailing view.
Rural Scotland: Rural Scotland welcomes the steps suggested for ensuring that developers engage effectively with local communities. One way of avoiding undue developer influence is through the preparation of village design plans, design briefings and so on. Rural Scotland has significant experience of drawing up village design plans through engaging the local community. The Rural Scotland initiated plan for the village of Tarland has been recognised as an innovative approach to village planning and has been adopted by Aberdeenshire Council as a favoured approach to preparing other such plans.
Scottish Civic Trust (and Civic Trust Network): Further to this, it is important for the government not think about community as a simply a collection of "local people". Ensuring that the local dimension is properly represented and articulated is very important and welcome, but the concept of "community" is much more varied. We hope that the Executive, and Parliament, understands that community engagement needs to take place on many levels, from the local to the national, and that this broad Kirk of community is adequately considered in any forthcoming legislation. The role of Community Councils should be reassessed and if additional support is required, then it should be met as part of these proposals. In line with the commitment to increase public participation in the planning process, there should be a statutory duty for planning authorities to establish and support a Planning Forum in their area. These fora could be used to discuss policy, projects, applications, etc and a few have already been established in Scotland. This featured the Getting Involved in Planning consultation.
Scottish Council for Voluntary Organisations: One of the most frequent complaints about the planning system is that communities are not engaged in the plan preparation and formulation process. Plans were prepared for communities, rather than with or by those communities. This lack of involvement for well informed members of the community can lead to developments being sanctioned by the planning process, despite strong local advice to the contrary, which can result in an environmental impact such as flooding. The current rights for individuals and communities are essentially of a reactive and not a participative character. There is a failure by both planning professionals and developers to sufficiently engage the wider public in the early stages of plan formulation. The involvement of elected members usually begins only when there are proposals that are (potentially) divisive. This lack of engagement can lead to individuals and communities increasingly adopting a negative approach to any kind of development or communities not responding to consultations. Planning professionals regularly report severe problems in engaging interest in more deprived communities, and spend the majority of their time coping with objections to even quite modest development proposals in more affluent areas. This issue of engagement is an area where the voluntary sector can make a significant contribution. The Scottish voluntary sector is now structured in such a way as to enable it to respond both on the basis of communities of place and communities of interest. In the first case, local Councils for Voluntary Service (there are 58 CVS, with a further three forums that perform broadly analogous functions) cover all of Scotland and provide the local focus for bringing the views of communities and voluntary organisations together. There is very strong evidence that planners at national and local authority level are not engaging with them to any significant degree, except in some rural authorities. There are also some 50 intermediary bodies that bring together those voluntary organisations with shared interests. Environment Link, with whose submission to this consultation SCVO agrees, is a very good example of the ability to bring together and synthesise views well evidenced comments from a range of substantial, membership based organisations. Many of the intermediaries have the ability to call on professional and scientific advice at least as good as that present in the public agencies, yet planning authorities would seem to have relatively less contact with them than other parts of local and national government. SCVO believes there are issues of social inclusion and social justice that require to be dealt with better in the planning system. Improvements to the planning process could develop a real sense of shared ownership of local development planning as a tool in community development. The way in which the Scottish voluntary sector articulates its views and consults its member organisations could be of considerable benefit to improving the evidential content of the planning process and calls on both the Scottish Executive and COSLA to enter discussions on how best to use these networks to increase participation and secure better shared ownership of the planning process in local communities and over larger areas.
Private Individuals
Bridges, Roy Professor: I note that it is intended to issue a Planning Advice Note on Community Engagement and it may be that my concerns about community councils will be taken up in that. As things stand with the present White Paper, however, it seems to me to be disappointing that so little formal notice is apparently taken of community councils.
Greenlaw, Mrs Floris H.: While public participation is to be encouraged and the views of local people sought, this process must be controlled by planning authorities. This should minimise the danger of vested interests within local communities manipulating the outcome. It must also be recognised that local people are often concerned about short-term issues e.g. employment, rather than longer term environmental and other issues. Planning gain can also introduce conflicts of interest within local communities. The professional judgement of planners, while rightly informed by public participation in making recommendations to councillors, should not be undermined, and this must be emphasised in the proposed PAN.
Holland, E Mrs: The opportunity for communities to have an effective input into their future should be strengthened. One way of doing this is to have clear guidelines for early public consultation and an assurance that community views will be given proper weight. Open consultation at an early stage coupled with an indication that views are being properly taken account of and acted upon should reduce problems and delays at later stages of the process. Practical improvements, particularly necessary in rural :areas where visits to service points can necessitate a round trip of 15 or more miles, would be: A4 size posters on display in sub post offices, 'village shops, village halls, travelling library Giving outline of proposal, date of public meeting, dates for objections. Circulation of this information as an insert in title community council newsletter
An insertion in the annual council tax informa1ion leaflet giving outline of any major planning proposals anticipated to be arising in the coming year
Mackenzie, Mary E: Given the emphasis in the White Paper on individuals' involvement in the planning process, there must be some "weighting" to their views or their voices will be drowned out by the media and professional developers.
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