4th September 2006

See Stroud District Council's 'Statement of Community Involvement' document at:

http://www.stroud.gov.uk/docs/localplan/sci.asp?did=sci

Comments by Martin Whiteside and Philip Booth on behalf of Stroud District Green party:

The document is well presented, clear and comprehensive. The process outlined suggests a serious and genuine commitment to informing and listening to the community – which to do properly involves costs, but can also bring benefits. While there are many good aspects to the proposed process there is unfortunately a flaw that undermines the whole process: there is no indication of the weight to be given to the views of the consultees. 

Without this the whole process becomes meaningless – just a statement of good intention. It is of critical importance that the weight given to community views is clearly defined (this doesn’t mean that the community should have a veto – but it is essential that their ability to influence the final decision is defined – otherwise the process can become a sham and community confidence in the process will not be maintained). Already for example there is evidence that some Parish councillors feel that they are consulted, but their views are not really taken into account.

We recommend that a mechanism to challenge instances when a community view, based, for example on valid planning grounds, is ignored without adequate reason – otherwise the SCI becomes a statement of intent with no redress. This process of challenge needs to be clearly defined and codified – otherwise it will result in confusion.

Parish Plans are only mentioned in section 6.7 and no indication is given of the relative importance of these documents in planning terms or how they will be used. This creates the risk that the community will be encouraged by SDC and the government to do lots of voluntary work in creating their plan, only to feel they are being ignored when it comes to real planning decisions. This does not provide an incentive to sustainable community involvement.

There are also some other specific issues:

4.3 – The relative importance of the Sustainability Appraisal is not defined. We understand further work is being done on this. We would like a much clearer statement regarding the role and weight of the SA will have in decision making.

Fig 4 – Consultees are grouped in relation to their knowledge of the planning system. It is not clear why this grouping is used and is a bit simplistic. It might be useful to point out that local people often know most about the local issues and are likely to be most affected by decisions – stressing their local knowledge and importance rather than their lack of knowledge of planning.

12.9 – The publicity section suggests a very limited and narrow use of site notices. We would like to see this expanded. Site notices are an important way of raising the issue of a development at a public level – and may be particularly important when trying to reach ‘hard to reach groups’. Often people and businesses who are not neighbours can be affected in ways that are not guessed by planning staff. 

Fig 7 - This is misleading – the majority of applications which don’t fall into either of the categories listed under those requiring site notices or the very limited list of those not requiring site notices have been left-off the diagram. In fact the text suggests that the default position is ‘No site notice’ and this is not what is shown on the diagram.

We would suggest that there should always be at least one prominent site notice – and ideally more. It is also important that the notice gives some information about the proposal – and doesn’t just tell the reader to look on the internet or go to the Council Offices – which can be a disincentive to ‘hard to reach groups’.  The example in Appendix 8 is an improvement but still fairly minimal. We would like to see if the information could be improved further and that coloured paper might be considered. It is also important that the notices to neighbours are similarly informative.

12.20 – Does this section not accord with recently adopted current practice?  Do not the five letters from the public or the Ward Councillor need to cite valid planning reasons?

Appendix 2 – Gay, lesbian, bisexual and transgender people are listed as hard to reach in planning terms. The author is perhaps confusing ‘discrimination’ with ‘hard to reach’.  However the list should specifically include those without access to the internet.  Those with disabilities should also include in the brackets those with visual or hearing impairment – as these are major barriers to engagement with public consultations.