PAPER C2

                                                                                                                                                                                                        

                                                                                                              Purpose : For Decision

                        REPORT TO THE EXECUTIVE

 

Date :              20 APRIL 2005

 

Title :               LOCAL DEVELOPMENT FRAMEWORK - STATEMENT OF COMMUNITY INVOLVEMENT

                                               

                        REPORT OF THE PORTFOLIO HOLDER FOR SUSTAINABLE DEVELOPMENT, ENVIRONMENT AND PLANNING POLICY

 

IMPLEMENTATION DATE : 2 May 2005

 

 

SUMMARY/PURPOSE

 

1.                  To  approve submission of the  Statement of Community Involvement  to the Government Office of the South East (GOSE).

 

RULE 15 - ACCCESS TO INFORMATION RULES

 

2.                  This report has not appeared on the Forward Plan due to an administrative oversight. Taking account of the election period, the next planned meeting of the Executive is 1 June 2005. The Statement of Community Involvement must be submitted to GOSE by the end of April 2005.

 

BACKGROUND

 

3.                  The Planning and Compulsory Purchase Act came into force on 28 September 2004 and it requires all local authorities to produce a Local Development Framework (LDF) within 3 years of commencement of the Act.

 

4.                  The Statement of Community Involvement (“SCI”) is one of the local development documents included within the LDF folder, and it sets out how and when the Isle of Wight Council will involve the community and key stakeholders in preparing the LDF (also known as the Island Plan) and dealing with planning applications.

 

5.                  The SCI covers two areas of community engagement.  Involvement associated with Island Plan and consultation on planning applications.  The document itself was subject to a six-week consultation period (detailed in section 8 of this report), and Appendix 1 lists the responses that were received, together with the Council’s response and proposed changes to the SCI.  Appendix 1 is split into two areas, with Section 1, dealing with involvement in the Island Plan and Section 2, consultation on planning applications.

 

6.                  The draft SCI has been circulated to members of the Executive, and copies are available from] Wendy Perera, ext 3596, email: [email protected], and also on the council’s website, in the planning policy section.

 


7.                  Whilst many of the comments received were in general support, their were issues raised which necessitate amending the SCI.  In summary these are:

 

·           The document needs to be written in plain English so that it is more easily understandable. – the document has been given to the Council’s Communications Section for revision to “plain English”.  A revised version will be tabled at the Executive meeting.

·           The document would benefit from a glossary of terms – a separate appendix for the glossary will be added to the document.

·           A more complete list of statutory consultees, stakeholders and other consultees is needed – a more complete list of consultees will be added to the document.

·           The section on consultation on planning applications requires more clarification to set out the existing procedure in more detail – this section will be revised to clarify the consultation process currently undertaken.

·           Major application thresholds.

 

Copies of the comments received from consultees, and a response to them, are attached as appendix 1.

 

STRATEGIC CONTEXT

 

8.                  The Island Plan is one of the main vehicles for implementation and delivery of the Community Strategy and the SCI is a formal part of this framework.

 

CONSULTATION

 

9.                  Consultation within the Council and with the Local Strategic Partnership (LSP) , stakeholders and local groups and agencies has been undertaken via a six-week statutory consultation period (Friday 11 February – Friday 18th March 2005).  An advert was placed in the County Press, encouraging local residents to make their comments on the document.  The document was also placed on the web site and paper copies were made available in Council reception areas and all libraries.

 

10.             Following formal submission to GOSE, there will be a further formal six-week consultation period.

 

FINANCIAL/BUDGET IMPLICATIONS

 

11.             The Council has been successful in achieving Planning Delivery Grant in both 2003/04 and 2004/05.  Resources have been committed from the PDG and from the Service Budget to produce this document as part of the Island Plan process.

 

LEGAL IMPLICATIONS

 

12.             The Planning and Compulsory Purchase Act 2004 requires every Local Planning Authority (LPA) to prepare and maintain an SCI.  Every SCI has to be submitted to the Secretary of State for independent examination.  If he is not satisfied with the SCI, the Secretary of State can direct the LPA to modify the same before it is adopted.  The SCI will form part of the statutory Local Development Framework.

 

OPTIONS

 

13.             To agree the revised SCI for submission to GOSE.

 

14.             To agree the revised SCI subject to further changes.

 

15.             The SCI is a formal part of the Island Plan and is required  under the Planning and Compulsory Purchase Act 2004.  The Council must therefore produce an SCI to comply with the Act.

 

16. The comments received as part of the consultation process have been considered and where appropriate, the SCI has been amended accordingly.  As part of the formal submission process, there is a further opportunity to comment on the SCI and any further amendments can be considered at that stage.

 

17. Option 1 is therefore the preferred option.

 

EVALUATION/RISK MANAGEMENT

 

18. Given that the submission and approval of an SCI is a requirement of the Regulations in order to progress the LDF, a failure to submit would leave the Council unable to meets its statutory requirements.

 

19. The Council could consider submitting a different SCI but this would lead to delays in progressing the LDF and it is considered that the documents currently set out in the Plan best align with the long-term objectives of the Authority, the Community Plan and the Area Investment Framework (AIF). 

 

20. One of the key aspects of the new Planning Framework is the need to set out clearly how the Council will engage the local community.  Failure to do so could lead to either financial penalties or reduced funding in future years from PDG.

 

RECOMMENDATIONS

 

21. That the SCI be approved for formal submission to the Government Office for the South East, subject to the proposed changes being incorporated.

 

BACKGROUND PAPERS

 

22. Local Development Scheme, submitted to GOSE, March 2005.

23. Consultation Draft Statement of Community Involvement, February 2005.

24. Planning and Compulsory Purchase Act 2004.

 

ADDITIONAL INFORMATION

 

25. Appendix 1 – List of comments received and responses to them.

 

Contact Point :           Ashley Curzon, Planning Policy Manager Tel 823557, email:  [email protected]

 

 

 

 

ANDREW ASHCROFT

Head of Planning Services

TERRY BUTCHERS

Portfolio Holder for Sustainable Development, Environment and Planning Policy.


Appendix 1:  Consultation responses and the Council’s response to them.

 


This is still being completed and will be circulated with the report on Monday.

 

  Section 1:  SCI General Comments

  Consult ID      4                    Unique Number        46.00

  Surname       Mills                           Agency    Brading Town Council

  SCI general Comment

  As a Town Council we do have free access to include information in Brading's newsletter which is delivered to every house in Brading, Adgestone and Yaverland on a monthly basis.  This could be used as a mechanism to involve the entire community of Brading in consultation.  If meetings,  workshops are to be held, please could these be at times convenient to those people who work, e.g. evenings.  Section 8 - could local youth council's be included in the list of stakeholders to be consulted?

  IWC Response

These comments are noted.  Parish and Town Council newsletters can be added to the table on page 14 with regard to notification for local residents.  We agree that wherever possible, meetings and workshops should be arranged at times convenient to those people who work, and a statement to this end will be added to paragraph 4 of section 3 (p7).  It is also agreed that the local youth council's be added to the list of key consultees.  This list is being revised to ensure that it is complete as possible

and includes all statutory consultees, stakeholders and local groups and agencies, as well as local residents.

 

  Consult ID      12                  Unique Number        36.00

  Surname       Diment                        Agency    Godshill Parish Council

  SCI general Comment

  This document has been produced only for IW Council officers, not the general public, as there is too much use of jargon with 11 different abbreviations making it very difficult to follow.

  IWC Response

  These comments are noted.  The document itself is now being revised in "plain English" and an additional glossary of terms will be added to ensure that it is as clear as possible to read and understand.

  Consult ID      13                  Unique Number        37.00

  Surname       Adams                        Agency    Gurnard Parish Council

  SCI general Comment

The general approach appears to be sound, but it must be adhered to by all the officers involved to ensure that the best interests of the Community are achieved.  This aspect has not always been followed in the past.

  IWC Response

Government guidance is clear in the duty it is giving to local authorities to ensure that local communities  are fully and properly engaged in the planning process.  As part of the formal submission stages of documents, the Council has to produce a statement of conformity with the SCI as proof that it has undertaken consultation in accordance with its SCI.  No change required.

Consult ID       24                  Unique Number        12.00

  Surname       Hampton                     Agency    TotlandParish Council

  SCI general Comment

Totally support the principle, providing community comments are listened to and acted upon.  There is no point if local community comments are ignored as the result of financial or government agendas carrying more weight.

 

  IWC Response

Support is noted.  Government guidance is clear in the duty it is giving to local authorities to ensure that  local communities are fully and properly engaged in the planning process.  As part of the formal   submission stages of documents, the Council has to produce a statement of conformity with the SCI as  proof that it has undertaken consultation in accordance with its SCI.  No change required.

Consult ID       25                  Unique Number        39.00

Surname         Farrant                        Agency    Ventnor Town Council

SCI general Comment

Development relating to the Esplanade and Eastern Esplanade should be specifically designated for an area development plan.

  IWC Response

This is not a matter for discussion as part of the Statement of Community Involvement.  The Local Planning Authorities programme of work is set out in the Local Development Scheme (LDS) which has been formally submitted to GOSE for approval.  No change required.

 

  Consult ID      26                  Unique Number        8.00

  Surname       Smith                          Agency    Wootton Bridge Parish

  SCI general Comment

  The Parish Council has carefully considered the above document and wishes to make the following comment.  The parish council advocates the need for the planning process to be more holistic and inclusive.  In this connection members support the distribution of information electronically to encourage people to fully participate.  Further more, the Parish Council would be pleased to offer its help and information centre to distribute information/accommodate displays connected with the LDF process.

  IWC Response

Support is noted.  The use of Parish and Town Council newsletters and information displays has been dealt with elsewhere in this schedule and will be included within the revised SCI.

  Consult ID      28                  Unique Number        13.00

  Surname       Keighley                      Agency    Yarmouth Town Council

  SCI general Comment

  Advertise with clear instructions and timescales (make more use of local notice boards and local meetings).  Identify any problems which may concern the community.  Consult with representatives from IW Council to local people and local venues.

  IWC Response

   The use of Parish and Town Council newsletters and information displays has been dealt with elsewhere in this schedule and will be included within the revised SCI.

 

 

  Consult ID      85                  Unique Number        11.00

  Surname       Flower                         Agency    Head of Property Services

  SCI general Comment

At times, the document was difficult to read, with numerous acronyms, abbreviations and buzz words, would be better to simplify and use plain English.

  IWC Response

These comments are noted and the document is being revised into plain English and will also include a glossary of terms.

  Consult ID      92                  Unique Number        25.00

  Surname       Griffiths                       Agency    Housing & Community

  SCI general Comment

  Section 8 - stakeholders- hard to reach groups should also include Physical and Sensory Disabled, Learning Disabled, Rough Sleepers and Travellers.

 

  IWC Response

  It is agreed that these groups should be added to the list of Hard to Reach Groups in Section 8.


  Consult ID      94                  Unique Number        38.00

  Surname       Hepburn                      Agency    Hepburns

  SCI general Comment

Overall I must say that I found it hard going working my way through this document.  It is full of good ideas, but really needs to be distilled.  You mentioned that the text will be in plain English.  I appreciate that you can't avoid the three letter acronyms, but some simplification would be in order.  I would also suggest that a glossary page is made available at the front of the document, for ease of reference as you work your way through.  Section 2 (iv), need to clarify who the stakeholder groups are and maybe what a stakeholder is.  Section 2 (v), need some examples.  Section 3 (i), there is also a    requirement to consult within the GDPO, which will remain for the time being, on DC applications.  Is local community different from community?  This is important for DC applications as how do you define the area you are to consult in.  Section 3 (4), ability to read is an issue.  I can remember during a plain English course there was a statistic of people who could not read.  This document is not written in plain English.  A good test it the vocabulary at an average reading age of 12, e.g. Para 5 should read your reply will help the council make the right decisions.  Section 5 (i) and (ii), what does comprehensive information campaign mean?  Section 5 (bullet points), add in adverts in planning department and anywhere else planning applications can be seen and County Hall reception.  Section 6, if this section is more overall, then maybe it should be closer to the front of this document.  Section 6 (i) needs simplifying as it is hard work to read.  Do not use the phrase "blue sky thinking".  Consultation Matrix - do not forget the business world.  For example the chamber of commerce often give talks at breakfast meetings.  How do you ensure that the citizens panel if a reflection of the broad community?  Section 8 should additionally identify people who cannot read; people with low incomes (transport costs, internet access), people who do not fill in questionnaires.

  IWC Response

These comments are noted and the document is being revised into plain English and will also include a glossary of terms.  A complete list of statutory consultees, stakeholders, consultation groups and agencies will be included within the revised document.  It is not considered necessary to give examples for Section 2 (v), as this section simply describes how the draft SCI was drawn up.  Section 3 describes an Islandwide process, hence local community refers to the whole Island.  The section on consultation for planning applications makes it clear about the process that is currently used, and states that pre-application consultation methods need to be agreed between the Council and developers/agents prior to consultation taking place.  Appropriate consultation will be agreed on a case-by-case basis.  It is agreed that the term "comprehensive information campaign" (Section 5(i)) needs further clarification   It is not considered necessary to move section 6 earlier in the document,  as previous sections set the scene about consultation generally, and this section refers specifically to the LDF.  With regard to the comment on the Citizens Panel, the panel itself has been chosen by recognised statistical methods, by the consultants who run the panel for the Council.  The need to       include further groups in section 8 has been dealt with elsewhere in this schedule.


  Consult ID      104                 Unique Number        47.00

  Surname       Burdett                        Agency    Isle of Wight Society -

  SCI general Comment

All distributed documents should contain a glossary of terminology.  The SCI is difficult reading for someone not used to the initials in use.  I assume that the LDF is aimed at performing the function of a County Structure Plan or Unitary Development Plan, but the procedure outlined in this SCI appears to be more complicated.  Cynics may claim that this has been engineered to ensure that not too many people want to be involved in the discussions.  I assess that 95% of members of the Isle of Wight Society do not know how Island Futures works or what its policies are.  There must be more investment in publicity

  IWC Response

These comments are noted and the document is being revised into plain English and will also include a glossary of terms.  The need for the Island Futures group to invest in publicity is a matter, which needs to be raised with the LSP, rather than as part of the SCI, and this comment has been forwarded to them.

  Consult ID      107                 Unique Number        3.00

  Surname       Fraser Boulton             Agency    Countryside Agency - SE

  SCI general Comment

We welcome the approach set out to involving the communities, especially communities in rural areas and the recognitions that residents in rural areas can be considered "hard to reach".

  IWC Response

  Support noted.  No change required.

 

 

  Consult ID      108                 Unique Number        17.00

  Surname       Dunn                           Agency    Environment Agency

  SCI general Comment

There is no mention of the Strategic Environmental Assessments or Sustainability Appraisals to support the DPD's, AAP's and SPD.  This is a very necessary part of the LDF process.  The Agency is happy to provide initial data and advice if required, please contact myself for further details.  With regard to the consultation process, as a recognised stakeholder, we would not only like to be involved but attend pre-meetings prior to any draft document being produced.  Your chapter 5 highlights preferred methods of communication, the newsletter idea would be useful for local communities and stakeholders alike.  A key part of the Agency's planning role is to liaise with Local Authorities on their core strategies, allocations and specific policies.  We would therefore wish to follow the Blue Sky approach highlighted on page 13 of the SCI, rather than wait to be consulted on draft documents and policies.  We would therefore be happy to meet with you to discuss further.

  IWC Response

Section 6 will be amended to clarify the role of SEA and SA and consultation on these processes.  The Council notes your willingness to be involved in the process.

 

Consult ID       111                 Unique Number        31.00

  Surname       Pearl                           Agency    Medina Housing Association

  SCI general Comment

Generally supportive of the Council's approach.  It appears to be inclusive of all potential groups on the Island.  However, please do not view housing associations only as interested in housing.  We are also large employers and have an interest in areas and neighbourhoods.

  IWC Response

The Housing Associations are key stakeholders in this process and will be consulted on all documents being prepared as part of the LDF process.  Support is noted.  No change required.

 

 

  Consult ID      118                 Unique Number        26.00

  Surname       Brownscombe              Agency    AONB Office

  SCI general Comment

Overall we appreciate that this is the first time a SCI has been prepared for the IW and one of the first in the country.  We appreciate that a good deal of effort has been made to demonstrate that this document has been prepared in accordance with PPS12 and meets the tests laid down by the Government in its guidance.  However, we feel that an opportunity to also show a genuine commitment to engage local people in meaningful consultation beyond what has been achieved in the past has not been fully embraced.  The introduction is too "dry" emphasising that the preparation of an SCI is a requirement under new legislation.  Whilst we appreciate that there is a significant amount of reference to SCI's in government regulations and guidance, we suggest it would be constructive to include a sub section on the Council's vision for community involvement and also the benefits of community involvement.  We also suggest that there is too much detail on the requirements and responsibilities to do an SCI, and there needs to be a statement on what an SCI is.  When referring to government tests we suggest it would be helpful to also give reference to a framework for assessing soundness and focusing representations on SCI involvement (Feb 2005) and Statements of community involvement and planning applications (Dec 2004).  We suggest the first sentence in section 2 (ii) be changed to "the local community and stakeholders will be consulted on the preparation of the SCI and any subsequent revisions.  Section 2 (iii), whilst information on the LDS is useful, we suggest that it is necessary to specify what relevance the LDS has to the SCI.  We suggest that it may be confusing to lay people for this section to elaborate on what a LDS is about without this explanation.  Section 3 (i), In reference to the ODPM we suggest that this should b expanded in full to "Office of the Deputy Prime Minister".    In reference to the audit, we suggest that it might be constructive in terms of "transparency and accessibility" to put a summary of the results in an appendix to this document.  Section 3 (ii), in reference to the range of key council documents used to assist the preparation of the SCI, we would suggest a more comprehensive list would be beneficial along with a further explanation of what information was relevant.  Section 3 (iii), in reference to the audit interviews, we suggest it might be constructive in terms of transparency and accessibility to put an example of the type of questions asked in an appendix to this document, along with a list of those interviewed.  Section 3 (iv), in reference to stakeholder groups, we suggest it might be constructive in terms of transparency and accessibility to include a list of those represented on the stakeholder groups appended to this document.  Section 3 (v), it is unclear why it is necessary to note that virtually all members of the local community had some local interest.  We suggest that there should be some reference tot he effort made to ensure traditionally hard to reach groups were represented.

  IWC Response

Your comments are noted.  The need to make the document easier to read and produce in plan English is dealt with elsewhere in this schedule. An additional appendix, which sets out how the SCI will be tested, will be included within the revised document.  It is not considered necessary to include your amendment suggested for 2 (ii), as the following paragraph makes it clear that there is a second opportunity for consultation when the document is submitted.  This two-stage process complies with the regulations set out in the Planning and Compensation Act 2004.  It is not considered necessary to amend the document with regard to the comment on 2 (iii).  Your comments on Section 3 are noted, but we would point out that the SCI itself is the result of the audit interviews, as people were asked about how the Council consults, and how it should consult.  There is no need to further add detail to Section 3, as this would make the document unnecessarily long-winded and would not add value to its use.

 

 

  Consult ID      118                 Unique Number        43.00

  Surname       Brownscombe              Agency    AONB Office

  SCI general Comment

Section 4 (i), we suggest the sentiments on this first paragraph referring to the importance that the IW Council places on ensuring all members of the community are given the opportunity to contribute to the preparation of the LDF, associated documents and development control matters, should be expressed earlier on in the document.  We suggest that it is not just about providing the opportunity, but recognising the benefits.  We suggest that reference to the statutory requirements in the following paragraphs are unnecessary and duplication as this has already been emphasised.  We agree that an easily identifiable process for consultation activities would be useful and would helps stakeholders on what they should expect.  We suggest that this process numbered 108 on ages 6 and 7 are steps or stages in the process and not "principles".  With regards to step1 - identify individuals and groups to be consulted, we suggest that a more comprehensive list of stakeholder groups and members of the local community should be listed in an Appendix  under the stakeholder groups listed in Section 8 of the document.  Whilst we appreciate that the regulations only require the identification of general consultation bodies, we believe an attempt at a comprehensive list would provide a useful checklist that will help to ensure a full and wide consultation, would demonstrate a genuine commitment and acknowledgement of involving these groups and it has been done elsewhere.  As well as a full range of local environmental and community groups, of which there are many on the Island, those that we believe should certainly be mentioned are the AONB Partnership; English Nature; Forestry Commission; English Heritage; Campaign to Protect Rural England.  We suggest that the LDF partners list is not comprehensive enough.  With regard to step 4 - the consultation programme, while it is stated that the council will ensure that all consultation methods take into account accessibility issues such as language, religion, physical access and impaired eyesight, we suggest it would be useful to specify how this will be done.  Similarly, step 5 - measuring the responses, more information on which the response will be measured, analysed and fed back.  Section 5 - in emphasising the links between LDD's and the Community Plan we suggest that this document include a summary of the main themes identified by the community in the community plan.  As reference is given specifically Theme 7, at least the title of this theme should be given.  We suggest that the officers project team should be given the same title as in Section 9, page 22 (ii), LDF SCI Officers Consultation and Communication Group.  Section 6 (ii), we welcome and support the statement that the IW Council will carry out a comprehensive information campaign prior to the start of any consultation activity on the new LDF.  However, we are concerned about the level of information thus far, particularly prior to the consultation on this SCI.  For example, we feel that more background information could have been included with the consultation response form.  A glossary of terms would have been useful.  As publishers of a community newsletter, we regularly ask for contributions from our partners.  We would be happy to include any material that would support the information campaign.  Section 7 (i), we suggest that the end of the first paragraph referring to the Council's overriding aim to provide an opportunity for all members of the local community and stakeholder groups to get involved if they wish should be deleted, as this undermines the importance of community involvement.  In reference to a comprehensive project plan, if this refers to the LDS then we suggest this should be explicit.  We also suggest it may be appropriate to specify where this may be viewed.  We suggest that key areas where the local community and stakeholder groups can be involved, as set out in the project plan should be specified in the SCI.  In light of our comments we suggest that the reference to the principles outlined in Section 3 should be replaced with "process".  Section 7 (ii), we suggest that the term blue sky approach should be explained, i.e. care should be taken not to raise hope/expectations over what can be achieved through community involvement.  With regards to the geographical split for consultation of DPD's we would suggest a separate category for AONB, or at least a sub-category within rural.  Section 9, we suggest that the key stakeholders identified as part of the community plan process should be listed in an appendix of this SCI.  With regards to the second paragraph, we suggest that you make reference to Appendix A.  We appreciate that general consultation bodies have been identified in accordance with the regulations, however we suggest that these are used as subheadings of a more comprehensive list.  This will give more support to the following commitment that the council will ensure that hard to reach groups are involved in the LDF process.  Section 10 (ii), we feel that there should be more detail on how the effectiveness of the consultation phases of the

LDF will be monitored.  Section 10 (iii), we suggest there should be more details on the scope of the audit including types of questions.

 

 

IWC Response

  A complete list of statutory consultees, stakeholders and consultation groups and agencies will be included within the revised document, together with a glossary of terms.  Your comment about use of the AONB newsletter to publicise the LDF is welcomed.  The plain English revisions to the document, will also cover many of the points that you have raised.  We do not consider it necessary to add a separate geographical category for "AONB" as consideration of issues relating to AONB is a key

  theme in many of areas already identified.

  Consult ID      139                 Unique Number        1.00

  Surname       Maclean                      Agency    Hampshire & Isle of Wight

  SCI general Comment

  The 8 principles clearly show the different stages of involvement and how the results of feedback will feed into LDD's.

  IWC Response

  Comment noted. No change required.

  Consult ID      145                 Unique Number        19.00

  Surname       Cole                            Agency    National Playing Fields

  SCI general Comment

The NPFA would like to be involved in the preparation of LDD's.  It is intended to prepare a set of model policies and to circulate these shortly, to every local planning authority.  This will provide the essence of the NPFA's representations at the preferred options stage.  At the submission stage, the NPFA will check the contents of the document and comment as it sees fit.  NPFA would wish to be consulted on Core Strategy, DC policies, and any SPD's which involve outdoor sports provision, provision for children's play and planning obligations.

  IWC Response

  Comments are noted.  No change required.

 

  Consult ID      152                 Unique Number        14.00

  Surname       Deakin                        Agency    Planning Advisory Group -

  SCI general Comment

Draft SCI fine in concept, but what weight is likely to be given to Parish Council and local resident opinions?  As in the past, it appears that any conflicting opinions may be disregarded, at the discretion of the inspecting officer (p17).

 

  IWC Response

  This is a comment relating to the planning application process, and is dealt with elsewhere in this schedule.  No change required to the SCI.

  Consult ID      199                 Unique Number        2.00

  Surname       Langford                      Agency    Country Land and Business

  SCI general Comment

  The CLA represents landowners and land managers and can act as a conduit to a diverse group of people on the Island who look after and maintain much of its countryside.  We welcome the general approach to be involved in the consultation process.

  IWC Response

  Support noted.  No change required.

 

 

 

  Consult ID      226                 Unique Number        15.00

  Surname       Hague                         Agency    Ramblers Association

  SCI general Comment

  We have been considering the Draft SCI and would indicate a desire to be involved in the Local Development Framework.  We would wish to be consulted on matters relating to the development of the LDF.

  IWC Response

  Your request for involvement is noted and your details have been added to the consultee database.  No change to the SCI required.

  Consult ID      227                 Unique Number        16.00

  Surname       Rose                           Agency

  SCI general Comment

(p6)  The draft document says that the Council will identify whom it will consult with at each stage of the LDF process.  Presumably these are the Isle of Wight LDF partners in appendix A.  I suggest that IW residents who ask to be involved in the LDF process are added to the list that the Council will consult with at each stage of the process.  Many people who would like to be involved in the LDF process, particularly those of us who are retired, are not members of any of the groups listed in

Appendix A.  The same point refers to information and community involvement on page 10.  Page 12 -   planning policies and proposals can and often do, have significant transportation implications.  This involves considering the implications for all modes of travel - including by foot, on cycle, by public transport, as a car driver, as a passenger in a car, bus, ferry, as well as commercial vehicles.  Clearly parking policies and proposals are a key part of the consideration of transportation implications.  Transportation should therefore be included in the page 13 list of key development plan developments.  Page 20 - I have already mentioned the possibility of local residents who are not members of any of the groups listed in appendix A being added to the list.  When considering which local residents to involve in a specific consultation, it is important to remember that many people often live, work and/or shop in a completely different areas.  For example, residents from many parts of the Island will be interested in the development of policies and proposals for Newport.  They may, for example, live many miles away in rural areas without public transport, but come to Newport to shop and/or work.

  IWC Response

  The need to a complete list of partners, stakeholders and consultees is dealt with elsewhere in this schedule.  We would encourage individuals to become involved in this process, as their views on the future role of the Island are just as valid.  Issues related to transport and car parking will be dealt with in detail in the Development Control Policy DPD, listed on page 12.

 

 

 

  Consult ID      228                 Unique Number        18.00

  Surname       Stubbs                        Agency    National Trust -

  SCI general Comment

Following on from the operational principles for community involvement established by PPS1, we would like the Isle of Wight to consider how the SCI delivers the frontloading of involvement in which policies should provide opportunities for participation in identifying issues and debating options from the earliest stages.  Pages 6 and 7 do refer to these concepts but the document would benefit from an overarching statement of frontloading principles so that all interested parties are aware of the Council's aspirations from the very start.  Page 10 - a number of methods are listed to promote community involvement in the new LDF.  These methods are comprehensive.  Page 13 proposes a pre-draft scoping exercise.  Again this is very welcome part of the consultation process.  It would be useful to know who this scoping exercise will feed into the community involvement principles, which itself will deliver public involvement ahead of the formal channels.  Page 12 - the National Trust would be very keen to become involved in the public consultation on various DPD's, AAP's and SPD's.  We have assumed that protection of landscape and AONB's will fall within the context of SPD's.  Page 14 identifies various mechanisms for notification and consultation.  We would recommend that the focus group and workshop section be expanded to include planning for real and enquiry by design methods of public consultation.  We note that the countryside agency is identified as an LDF partner in appendix A.

  IWC Response

Your comments are noted, and many of the points you have raised will be dealt with as part of the revised version "plain English" version.  This will produce a document, which is more easily understood and describes in more detail some of the issues and processes mentioned in the SCI.  The protection of landscape and AONB's will fall within the context of the Development Control DPD in the first instance.  Your suggestions for amendments on page 14 will be incorporated.  Your request to be involved in LDF process is noted.

  Consult ID      231                 Unique Number        24.00

  Surname       Nunn                           Agency    Tacklers Boating & Fishing

  SCI general Comment

  A whole area is missed by the approach.  Groups may be interested in large residential, retail and warehouse schemes, but the creeping infill development is of concern to small groups or individuals.  This is not seriously addressed.

  IWC Response

Individuals interested in "creeping infill" through individual planning applications are given the opportunity to comment on applications through the statutory consultation process set out in Section 7.

 

 

 

  Consult ID      233                 Unique Number        9.00

  Surname       Hatchwell                    Agency

  SCI general Comment

I agree with this draft SCI that early public and other stakeholder participation is key to a better LDF, and with much of its content, very generalised at this stage.  However, I have serious misgivings on certain broad-scale aspects, and also some more specific practical aspects.  The advisory group of elected councilors that will oversee the work of the Island Futures Theme Group 7 - ensuring quality of the built environment, in developing the LDF, is a reasonable suggestion.  However, I am concerned as to whether they will have sufficient background experience to adequately scrutinise the process.  IW Council is right to "prepare and carry out a comprehensive information campaign" before any consultation activity is carried out.  However, this process also needs to be continued meaningfully as the details of the draft LDF take shape.  A major problem with public discussion of the LDF is that it is perceived as too broad, too abstract and too dry for the majority of the people to comment on, even for many who are well informed.  It is only when more specific, local threats are perceived that weaknesses in the LDF are likely to be exposed.  This is, the devil will always be in the detail.  Assuming public acceptance of development proposals at local level simply because they are claimed to be within the terms of the UDP, or indeed LDF is dangerous even if true, as was well illustrated at Ventnor in a heated meeting over the controversial Esplanade proposals, where residents felt they were facing a fait accompli on high rise flats and mixed use policy being misinterpreted as industrial units on the seafront.  This is certainly not to say that public consultation at the strategic level, but rather that it would be more successful if carried out in parallel or indeed in conjunction with local consultations, rather than beforehand, so that particular examples of conflict and their resolution can inform both the public and planners in the importance of such issues within the strategic plan.  Also, while there is to be consultation in one way or another on the LDF and on the specific segments of which it is composed, there appears to be no direct means by which stakeholders, including residents can influence the even broader strategic framework being set in place by Island Futures (LSP), which will in many ways set the terms of reference for the LDF.  The Island First coalition has, for example, been attacked for pursuing an uncritical development agenda, not least through the UDP.  It is of course true, as I have said, that it is difficult for the public to comment on such a broad-scale strategy document, but some form of anticipation in this is democratically vital nevertheless.  Again, linking local-scale discussion with this overall strategic discussion is one way of drawing in public interest.  Will the audit report presented to IW Council and drawn upon in its Statement of Community Involvement be available for public inspection?  On a more specific example of community involvement in the forthcoming LDF, but with wider implications, how will the IW Council integrate protection rights of St Lawrence residents to be consulted on future management of the locally important aquifer when it has approved, in spite of public opposition, a drainage scheme for the A3055 that threatens its sustainability?  An obvious stakeholder for consultation in this area is the Undercliff Defence Committee.

  IWC Response

The elected members have a series of committees whose function is to scrutinse work.  They are trained in doing this.  Your comments on involvement at strategic and detailed level are noted.  Indeed, the Council is not expecting that there will be many individual residents who would wish to be involved in the development of "strategic" documents.  Your comments with regard to the LSP are noted, and whilst it is not appropriate for inclusion in the SCI, it should be noted that the Community Strategy, which is the strategic document produced by the LSP was as a result of an extensive consultation exercise.  Island Futures is not the same as Island First.  Island Futures are the Local Strategic Partnership Group, whilst Island First are the ruling Council group.  The audit report mentioned in the SCI was produced for the Council's Communications Section.  Any group, which wishes to become involved in the process, can get involved.

 

 

  Consult ID      235                 Unique Number        4.00

  Surname       Kneale                        Agency    Southern Water

  SCI general Comment

According to the ODPM's Companion Guide to PPS12, the purpose of the SCI is to outline the participation techniques to be used for different types of local development documents at different stages of their preparation.  The Isle of Wight draft SCI broadly meets this objective.  It outlines the methods of communication, the stages at which consultation will take place and the groups that will be consulted.  The consultation and information matrix on pages 14-15 indicates that statutory consultees will receive a letter notifying them of each consultation event and that the method of participation is workshops.  Southern Water considers workshops to be appropriate at the early stages of LDD preparation.  However, to ensure effective and efficient communication, such events should allow participants to focus on topics of particular interest.  One-to-one meetings with Planning Officers would also be appropriate at early stages.  At the preferred options and submission stage, receipt of consultation documents and written response would be more appropriate.  This method of consultation is not stated in the draft SCI.  Furthermore, consultation at the submission stage is not specifically states, as far as we can ascertain.  Whilst the draft SCI broadly meets the objectives laid down in the Companion Guide to PPS12, the guidance provided is general.  The method of involvement is not tailored to the stage of preparation, and guidance on individual LDD's is not provided.  From Southern Water's point of view the appropriate methods of involvement depends on the stage of preparation.  Topic-based workshops and one to one meetings with Planning Officers are appropriate at the early stages of preparation, but at later stages, receipt of consultation documents and written response would be more appropriate.  Furthermore, the type of LDD may determine the stage at which involvement would be appropriate.  Southern Water would anticipate participation at the pre-production stage of the Core Strategy and the Development Control policies document, but would not expect involvement in the site allocations and area action plans until initial decisions have been made with regard to the likely location of development.  This is because assessment of water and wastewater capacity cannot take place with appropriate robustness until a holistic picture of the location of development emerges.

  IWC Response

Revisions will be made to make clear the relationship between preparation stage and consultation and responses methods used.

 

 

  Consult ID      235                 Unique Number        41.00

  Surname       Kneale                        Agency    Southern Water

  SCI general Comment

  In our view, the draft statement could be strengthened in terms of identifying stakeholders and partners to be consulted.  Groups are identified in Section 8 and Appendix A lists LDF Partners.  Southern Water, the water and sewerage undertaker is not listed.   As we have received notification of SCI consultation we assume we are included, but it would be helpful if specific consultation bodies were identified in an appendix.  This would enable bodies that expect to be consulted to check if they

  have been included.

  IWC Response

The revised SCI will include a complete list of statutory consultees, stakeholders and other consultees for the process.

  Consult ID      235                 Unique Number        42.00

  Surname       Kneale                        Agency    Southern Water

  SCI general Comment

  We assume that the matrix on pages 14-15 applies to all key DPD's, as indicated by the title, even though the table itself makes reference to the Core Strategy.  To improve clarity, it would be helpful if these references were removed, and replaced by DPD's.

  IWC Response

  Your comments are noted and references to Core Strategy will be deleted.

 

 

  Consult ID      236                 Unique Number        40.00

  Surname       Jackson                      Agency

  SCI general Comment

The importance of community involvement cannot be over emphasised.  The general public, who ultimately pay for public development initiatives through taxes, must be presented with all the facts, especially statements of environmental impact, in sufficient time to prevent half-developed projects such as SEEDA's East Cowes project running forward out of control.  I attach high priority to early promulgation of developing policy for strategic transport links.  For too long transport policy has been allowed to evolve through short-term first-aid reaction to transport problems, for example, the Red Funnel Trailer Park.  The IW Council must recognise that the nature and volume of ferry traffic bear no resemblance to the traffic handled when the River Medina, Fishbourne and indeed Yarmouth vehicle ferries were established many years ago.  The IW Council must present its views on options for the long-term future including fixed link and new ferry terminals away from urban areas.  The existing urban infrastructure of the IW is not longer capable of absorbing further increases in ferry traffic.  Ferry traffic must either be pegged at the  present level of other strategic transport routes and

mainland links generated.

  IWC Response

  Your comments are noted, however your detailed concerns with regard to transport issues are not a matter for consideration as part of this consultation process.  No change required.

  Consult ID      237                 Unique Number        35.00

  Surname       Ricks                          Agency    Boyer Planning

  SCI general Comment

  We generally support the principles contained within the SCI.

  IWC Response

  Support noted.  No change required.

  Consult ID      238                 Unique Number        30.00

  Surname       Eskdale                      Agency    Vectis Response Indicators

  SCI general Comment

Seems complicated - but this is not your fault.  Using response indicators to measure public response (meetings etc).  This is an Island invention and I can provide details.

  IWC Response

The document is being revised into "plain English".  Your comments on the use of response indicators are noted.

 

 

  Consult ID      239                 Unique Number        28.00

  Surname       Hunt                           Agency

  SCI general Comment

  How does the IW Council propose to identify individuals to be consulted?

  IWC Response

  The Council does not propose to identify individuals to be consulted, but will use adverts, posters, information in newsletters etc to ensure that any individual who wishes to become involved can do.  No change required.

  Consult ID      240                 Unique Number        27.00

  Surname       Blackburn                    Agency

  SCI general Comment

Section 4 - planning team should include parish council representation.  Section 6 - when will the Citizens panel be set up?  Section 8 - will opinions of the parish councils and the public be given the proper attention?  Where will the VDS and Parish Plan documents figure in this consultation process in the future?

  IWC Response

  The Parish and Town Councils are statutory consultees for the LDF and will be given the opportunity for involvement early in the process.  In addition, the LSP has includes Parish and Town Council representation.  No change required.

 

 

  Section 2: SCI Community Involvement in the DC Process

  Consult ID   2                  Unique Number   10.00

  Surname    Phillips                       Agency    Arreton Parish Council

  SCI comment    It would be helpful if site visits could be part of the process on controversial applications.

  IWC Response   Site inspections are a valuable part of the Development Control process.  Nonetheless it is felt appropriate at this stage to leave the choice of site inspections to the Development Control Manager, the Chairman of the Development Control Committee and ultimately, the committee itself.  No changed needed to the SCI.

  Consult ID   4                  Unique Number   46.00

  Surname    Mills                           Agency    Brading Town Council

  SCI comment    We do have grave concerns regarding pre application consultation:  We firmly believe  that any consultation regarding controversial or major development should be carried out by an independent person/body.  It cannot  and should not be undertaken by the developer, this will lead to accusations of bias; it will be divisive to communities and will leave both the LPA and the applicant in an impossible situation.  How can the IW Council ensure that consultation undertaken by the developer (applicant) of a major or controversial scheme correctly reflects the views of the community and is unbiased?  We believe that being a small Island, major developments will undoubtedly impact on the entire Island community, therefore it should be consulted, as opposed to only the key stakeholders.

  IWC Response   In accordance with the new legislation it would be perfectly appropriate and practical for a developer to carry out pre-application consultation.  Similarly, it would be possible for the wider public to have an involvement in this process it if is suitably and adequately advertised.  No change needed to the SCI.

 

 

 

  Consult ID   5                  Unique Number   32.00

  Surname    Mariner                       Agency    Brighstone Parish Council

  SCI comment    Councilors have always understood that they have only 15 days in which to respond to a planning application.  Paragraph 3 states that 21 days are allowed for comments.  Is this a change or always been the timescale?  The applicant/developer will automatically make sure his consultation is positive and responds to his wishes.  Is this adequate?  For sites that are sensitive to development and may fall through the  normal development plan processes receive smaller amounts of discussion/consultation, etc.  Is this correct?

  IWC Response   The 21 day period is the period that is set for Parish Councillors and indeed members of the public to comment on a planning application when it is submitted.  It is impractical to identify threshold for pre-application discussion.  Inevitably, this may mean that certain more sensitive sites do not receive the same extent of pre-application consultation than would otherwise be the case for other larger schemes.  However, this matter can be rectified during the statutory consultation process once an application is submitted.  No change needed to the SCI.

  Consult ID   12                Unique Number   36.00

  Surname    Diment                        Agency    Godshill Parish Council

  SCI comment    Godshill was not consulted formally over the closure of the public toilets opposite the Griffin and the IW Council no longer show much involvement in the Village Partnership  with very little response to communications from its Secretary.

  IWC Response   The comments of the Parish Council refer to a specific event, which is not directly relevant to this consultation process.  No change needed to the SCI.

  Consult ID   13                Unique Number   37.00

  Surname    Adams                        Agency    Gurnard Parish Council

  SCI comment    Local opinions expressed by Parish and Town Councils should be addressed and carry a higher profile than at present.

  IWC Response   All comments received from town and parish councils are properly addressed by either planning officers using their delegated powers or by the Development Control Committee.  The profile and weight to be given to comments from parish and town councils will vary on a case-by-case basis and will directly relate to the relationship between the various comments and those issues which are directly material to the consideration of any planning application.  No change needed to the SCI.

 

 

 

  Consult ID   15                Unique Number   23.00

  Surname    Parsley                       Agency    Nettlestone and Seaview Parish

  SCI comment    When comments on planning applications are acknowledged it would be helpful if a reference number was contained on the acknowledgement.

  IWC Response   This comment is accepted.  No change needed to the SCI.

  Consult ID   17                Unique Number   33.00

  Surname    Jones                         Agency    Niton and Whitwell Parish Council

  SCI comment    There should be specific liaison in person with properties adjoining the property subject of the planning applications.  The planning department has the expertise to do this well.  The possibility of case officers attending Parish Council meetings should be explored.

  IWC Response   Personal liaison with properties adjoining an application site would be prohibitively expensive.  The service is setting out to provide planning surgeries in customer facing service points throughout the Island.  The possibility of planning case officers attending parish council meetings would need to be carefully explored before it could be trialed.  Planning officers currently do not attend public meetings during the processing of a planning application.  No change needed to the SCI.

  Consult ID   24                Unique Number   12.00

  Surname    Hampton                     Agency    TotlandParish Council

  SCI comment    Pre-application consultation should also apply to residential schemes of less than 30 units.  Particularly multistorey blocks in residential areas (Wilmington & Clifton care home in Totland).

  IWC Response   It is accepted that many smaller residential schemes can prove to be more controversial than larger allocated schemes.  The reason for suggesting a particular size of scheme is to make pre-application consultation more selective.  No change needed to the SCI.

 

  Consult ID   28                Unique Number   13.00

  Surname    Keighley                     Agency    Yarmouth Town Council

  SCI comment    Ample notice to comment at our meet monthly at a Town Council meeting.  If it is an issue involving affecting the community, consultation should be made to the public at  a local venue arranged by Clerk.

  IWC Response   These comments are noted.  No change required.

 

  Consult ID   40                Unique Number   20.00

  Surname    Fleming                      Agency

  SCI comment    Site visits by members prior to DC meetings would assist in decisions and save time with deferments etc (not all applications).

  IWC Response   These comments are accepted in principle.  It is not clear from these comments whether it is intended to imply that members visit all sites prior to the determination of such applications at the Development Control Committee meetings.  In practice, it is suggested that the decision whether or not to have a site inspection should continue to lie with either senior officers, the Chairman of the Committee or the Committee itself.  No change required.

  Consult ID   85                Unique Number   11.00

  Surname    Flower                        Agency    Head of Property Services

  SCI comment    It is a very good idea to get public involved in consultation and decision-making, giving the community more involvement in larger developments.  However, it will lengthen the project programme and increase the cost with extra time spent discussion schemes prior to planning submissions.

  IWC Response   These comments are noted.  Whilst pre-application consultation will possibly increase the overall cost of the project, the proper discussion of the issues before the formal submission of the application may reduce rather than lengthen the overall project programme and in some cases has speeded up the processing of planning applications.  No change required.

 

  Consult ID   92                Unique Number   25.00

  Surname    Griffiths                       Agency    Housing & Community Support

  SCI comment    Pre application consultation should also include any scheme that provides affordable or social housing as part of the development.

  IWC Response   These comments are noted, however in practice it may be too onerous to include all such schemes given the varying thresholds across the Island.  No change required.

  Consult ID   94                Unique Number   38.00

  Surname    Hepburn                      Agency    Hepburns

  SCI comment    The Section on Development Control is too vague and it does not distinguish between outline and full applications.  It also asks the question, what would happen on a reserved matter application?  I would personally avoid the threshold for industrial premises as you will need the flexibility to fast track an application that would promise say 100 jobs.  Generally it is hard to remember any controversial employment-generating site.  Section 7 (i), most groups who want to be involved are already, by reading the County Press.   Need to define what is meant by real community involvement.  How do you know before hand what schemes are likely to be controversial?  Thresholds:  what happens with outline applications?  E.g. 0.5 ha could be 20 units or 40 units and still meet density requirements.  Employment and retail schemes  - are these site area of building size?  Does this include change of

                           use?  Section 7 (iii) , what about full application?  Add "for registration/validation" to the end of point 3.  Section 7 (iv), bullet 1, you should already have done this through the Council's SCI.  Table for consultation - how does this tie into the thresholds previously mentioned?  Are they the first hurdle?  For example, a scheme of 25 units on a brownfield site in the floodplain (not uncommon) falls within those 3 but not the first set of thresholds.  The community would be more interested in this, than an employment scheme of 4,650 meters.

 

IWC Response     The comment on the distinction between outline and full applications is noted and accepted.  The comments on employment applications are noted.  However, it is considered appropriate to retain some degree of threshold, which will require pre-application consultation.  The comments on the involvement of particular groups is  noted.  However, a continued simple reliance on traditional methods such as advertising in the County Press is considered to be inadequate.

 

 

  Consult ID   104              Unique Number   47.00

  Surname    Burdett                       Agency    Isle of Wight Society - Executive

  SCI comment    The Council planning website is very easy to use and allows us to monitor and comment on applications Islandwide.  There is also good availability of policy documents such as SPG's and Conservation Areas.  The main problem is that not everyone has a computer linked to the internet using cable or broadband.  To ensure full communications the IOW Society needs paper copies of policy documents for most of our Executive.

  IWC Response   These comments are noted.  When consultation documents are advertised, there is always a contact name and number from where you can obtain paper copies.  No

                           change required.

  Consult ID   108              Unique Number   17.00

  Surname    Dunn                          Agency    Environment Agency

  SCI comment    We fully support chapter 7, whereby you promote that developers carry out pre-application discussions and where relevant, we would be happy to be party.  However, under the types of development for discussion, we would wish to add "development falling within Zone 3 flood risk areas".

 

  IWC Response   These comments are noted. It is not proposed to amend the thresholds to include development falling within Zone 3 Flood Risk Areas  The thresholds set relate to those which relate to applications which will automatically be dealt with by the Development Control Committee, rather than under delegated procedures and is not proposed to amend them.

 

 

  Consult ID   118              Unique Number   26.00

  Surname    Brownscombe             Agency    AONB Office

  SCI comment    Section 8 (i), with regards to the availability of applications for inspection by the public, we suggest that you specify locations where this can be done.  With regards to seeking views from local amenity groups, we suggest more information is provided, for example how?, when? And is it criteria based?  Reference again to the Government’s intention for favour early community involvement undermines any acknowledgement by the IW Council of potential benefits.  With regards to the types of applications developers will be encouraged to carry out pre-application consultation on we make the following comments:  30 units for residential schemes is  too high, particularly with the DoE classification of major residential development is 10 or more units' if environmental impact regulations are triggered, then we would suggest all developers should carry out pre-application consultation, including major

                           road schemes.  Section 8 (ii), in our opinion reference to the process for consultation outlined in section 3 is unnecessary and confusing, considering the following section, which we broadly support.  Section 8 (iv) with regards to the first bullet point, we suggest that a full comprehensive list appended to the SCI would be beneficial to help ensure all the key stakeholders and members of the local community are identified.  With regards to the table on p19, we suggest that the levels of controversy or objection should not be the sole defining criteria for selecting types and styles of community involvement.  Community involvement can generally raise the standard and quality of development.  We suggest that development briefs and workshops are very useful tools and should be considered as an approach more than is indicated on this table.

  IWC Response   The section on planning applications is being revised to give clarity to the process that is currently used.  This will include more detail with regard to how the Council currently makes applications available for public inspection.  Discussion on thresholds is dealt with elsewhere in this schedule.

 

 

 

  Consult ID   139              Unique Number   1.00

  Surname    Maclean                      Agency    Hampshire & Isle of Wight Wildlife

  SCI comment    The Council encourage developers/applicants to consult the public on planning schemes pre planning application, at what stage will the council become involved, will  this only be at post application?  If there are any potential problems or public objections identified at the pre application stage how will the Council show that they have been addressed.

  IWC Response   The developers will be asked to submit a consultation statement with their application (p18 iii 3).  This document will need to be considered as part of the application process. Point three is to be expanded to read "....  This is a statement of the results of the consultation carried out before a planning application is submitted".

  Consult ID   145              Unique Number   19.00

  Surname    Cole                           Agency    National Playing Fields Association

  SCI comment    The NPFA has no desire in the foreseeable future to be consulted on planning applications as a matter of routine.  Where it learns of a proposal of special interest, the NPFA will make contact with local planning authorities and request a copy of that planning application accordingly.

  Consult ID   191              Unique Number   34.00

  Surname    Horton                        Agency    Lake Community Partnership

  SCI comment    We would like more consultation on planning decisions and enforcement of them, particularly in the case of environmental issues.

  IWC Response   These comments are noted, although at this stage, it is not an issue to be addressed by the SCI.  The comments have been passed to the Development Control team.  No change required.

 

  Consult ID   199              Unique Number   2.00

  Surname    Langford                      Agency    Country Land and Business

  SCI comment    We welcome the opportunity to be involved.  We have a concern that the timescale for such planning applications will be greatly increased.

  IWC Response   These comments are noted.  Whilst pre application consultation will increase the timescale within which applications are developed, the timescale for determining such applications will not necessarily be greatly increased.  No change required.

  Consult ID   226              Unique Number   15.00

  Surname    Hague                         Agency    Ramblers Association

  SCI comment    We find that the present system relating to applications with a right of way is not satisfactory.  Such applications are difficult to identify unless they are advertised separately - and this seems to be at officer discretion.  It would seem to be appropriate for consultation on all applications where a right of way runs through or

near the land parcel.  However, we note section 7 refers to specific large developments.  We would indicate a wish to be involved in prior consultations for those specific cases, both from a rights of way and a countryside aspect.

  IWC Response   Whilst we are sympathetic to these comments, it would be impractical to require pre-application consultation on all applications where a right of way runs through or near the parcel of land.  No change required.

 

 

  Consult ID   228              Unique Number   18.00

  Surname    Stubbs                        Agency    National Trust - Thames,Solent

  SCI comment    We would welcome some guidance here on how the web could be harnessed for planning application consultation so that application details van be displayed on-line and comments submitted by this medium.  This is currently being piloted by London Borough of Richmond-upon-Thames.  It provides interested parties with a real benefit.

  IWC Response   These comments are noted, and we would point out that all current planning application details and comments submitted on them are already included on www.iwight.com.  The benefits of this practice have already been realised.  No change required.

  Consult ID   231              Unique Number   24.00

  Surname    Nunn                          Agency    Tacklers Boating & Fishing Club

  SCI comment    Planning consent when given is not followed through by Planning (Binstead Brook) now a main river has experienced virtually no flow control or maintenance, with developments appearing annually.  This has to be stopped by not by this plan of action.

  IWC Response   Whilst these comments are noted, they are specific to post decision-making.  The SCI is a document which sets out how local communities can become involved in decision-making and the comments themselves cannot be addressed by the SCI.  No change required.

 

  Consult ID   233              Unique Number   9.00

  Surname    Hatchwell                    Agency

  SCI comment    The threshold for pre-application consultation appears to be set too high (30 housing units is large by Island standards), particularly given the impact of even medium sized  development schemes on a small Island community, and local individuals in affected areas, not just stakeholder groups need to be consulted as far as possible in sensitive applications.  In this context, it is indeed important to consult neighbouring residents, but not only at the discretion of the inspecting officer, where developments  with multiple units/large floorspace, and involving substantial change of use are concerned.  The document refers to this procedure in relation to controversial development applications, but under the proposed system, fundamental and very unpopular changes to the Ventnor Esplanade would not qualify for pre-application consultation as of right.  A key failing of consultation where it does occur is that it is perceived as very much a one-way process.  Anyone wishing to object or comment   on any application can send their views, in writing to the head of planning services, or the identified case officer within the time specified, to ensure that any comments can be fully taken into account before the decision is made.  Yet there is no way of knowing whether comments have been taken into account, as only standard letters are received in reply, and often no acknowledgement at all, with objections being lost on too many occasions.  There is a great deal of cynicism over this, not least in the case of Undercliff Drive, where strong, detailed issues were raised, but never officially responded to.  Nowhere in these proposals is there a cast iron commitment to interactive debate between council officials and individual residents, as opposed to stakeholder groups, except perhaps at the pre-application stage.  It has even been claimed by Council that public meetings on live applications is against its policy, though no one can actually quote where this rule appears.  Obviously this leads to great frustration and cynicism in the democratic process, risking increased planning conflict, as it is only when details of proposals are published that most people feel able to comment on it and to raise appropriate questions or objections.  The Council must urgently change its stance on this if it wishes to regain trust and democratic credibility.  The proposals suggest pre-application public meetings for controversial proposals and/or contrary to the UDP, but not where these are in line with the UDP.  However, in view of what I have said on the difficulty of catching public attention at the strategic level, this risks continuing conflict at local level.  If there is sufficient concern about an application, even if within the broad terms of the UDP, it should still be subject to broad public acceptance in a given locality.  In some cases, for example, in the case of Undercliff Drive proposals, it may be argued, wrongly in my judgement, that the scheme is within the terms of the UDP, but the prevailing situation at the time of the UDP was approved may have radically changed - in this case for example, such a damaging proposal was not foreseen.  A key source of irritation with the handling of controversial development planning applications is that materials changes are made to applications on the hoof with alarming regularity, making public and stakeholder group comment all the more difficult.  Nor is it clear which criteria will be used to select the specific stakeholder groups that get a voice early on in consultations, as opposed to categories that have been identified. Will there be an appeal process without cost for excluded groups who feel aggrieved?  Where a highly controversial and unpopular scheme is approved by Council in spite of objections, the cards are stacked against communities, who have few options open to them other than costly legal action.  Confrontation with a democratically elected Council should not have to occur with true consultation, but all too frequently does, with access to environmental justice an increasingly important issue.  Complaint procedures too need to be improved.  There is a feeling that the Council planning policies are pursuing a development at any cost strategy which renders futile any objection on social or environmental grounds.  This urgently needs to be addressed, not by propaganda, but by genuinely listening and responding to residents, not merely to business.

IWC Response     The comments on the threshold for housing schemes has been commented on elsewhere in this schedule.  It is accepted that certain schemes which would not exceed the various thresholds set out in the SCI will nevertheless be unpopular and controversial, and all applications are subject to a 21 day period of consultation during which time people can make their views known.  The comments on the one-way consultation process are noted.  Whilst the comments made by Dr Hatchwell are acknowledged and understood, it is, and will be impractical to respond in detail to the many letters of representation which are received on all types of planning applications.  The various comments on the effectiveness of existing proposed public consultation exercise are noted.  Fundamental to the planning process is the principle that all material considerations need to be properly considered and balanced by the decision maker.  This leads to obvious frustration on the part of objectors who frequently give differing weight to the various issues

                           involved in the determination of an application and in particular on those matters which they feel most pertinent to a potential refusal of the application.  The government has declined to introduce a third party right of appeal process and on that basis is would be inappropriate for the Council to introduce a local policy to this effect as suggested by Dr Hatchwell.  It is accepted that the development process is difficult to understand for many local communities and the increasingly tight processing deadlines set by the Office of the Deputy Prime Minister (ODPM) prevent or inhibit full public consultation.  The process of preparing an SCI and the implications that this places on development should give a far more extensive and wide-ranging ability for local individuals to become involved in the development process.  No change required to the SCI.

  Consult ID   234              Unique Number   5.00

  Surname    Bailey                         Agency    GVA Grimley (English Partnerships)

  SCI comment    Whilst we do not object to the suggested pre-application consultation techniques we would recommend that the consultation techniques used in each case be agreed between the applicant and the Council based on the nature and merits of individual planning applications.  We would also like it to be acknowledged that the table set out in part iv of Chapter 7 is to be used as a "guide" and not a definitive nor an

                           exhaustive list.

  IWC Response   Paragraph iii on page 18 makes it clear that an appropriate consultation programme should be agreed between the Council and developers at pre applications discussions.  Page 19 also makes it clear that the table is to be used as a "guide" to the types and styles of community involvement that Developers should undertake, however the table is not clear, and we will revise the Sci to discuss types of consultation that may be appropriate, rather than relate them to specific types of application.

 

 

  Consult ID   235              Unique Number   4.00

  Surname    Kneale                        Agency    Southern Water

  SCI comment    According to the TCP(General Development Procedure) Order 1995 and the provisions in the 2004 Act, water and sewerage companies are not statutory

                           consultees in relation to planning applications.  However, it is imperative that Southern  Water is notified of and given the opportunity to comment on planning applications that increase the demand for water and wastewater services.  If sufficient capacity is available, we will have no objection to the development.  If insufficient capacity is available, the development must be phased to coincide with provision of additional capacity.  This will ensure that a high level of service is maintained to both new and existing customers.  Connections to networks without sufficient capacity can result in poor water pressure, and failure to meet environmental standards in the treatment of wastewater as set by the Environment Agency.  It is also important that Southern Water is consulted on applications that may impact on the provision of water and waste water services to existing customers, for example if the proposed development affects access to and operation of Southern Water's assets.  These include underground mains and sewers.  Notification and early involvement can help to ensure that negative impacts are avoided or reduced.

  IWC Response   These comments are noted and it is vital that Southern Water are given adequate opportunity to comment on all development proposals.  This is currently encompassed  in the consultation procedures which the Local Planning Authority has with this agency.  There is no reason why Southern Water cannot be invited to participate in pre-application discussions on relevant applications.  No change required.

 

 

 

 

 

 

  Consult ID   236              Unique Number   40.00

  Surname    Jackson                      Agency

  SCI comment    Elected officials should make public their views and any special involvement concerning major planning developments so that their constituents are properly represented.  When statistical surveys are used to support a particular planning argument the survey catchment area must be indicated and total size of that

population given against the sample size.  This would prevent statistics being manipulated to support cases that are in reality opposed by a significant majority.

 

IWC Response     Isle of Wight Members are bound by the Council's code of practice for Officers and

                           Members in dealing with planning applications.  The various comments on statistics

                           and statistical matters are noted.  No change required.

 

  Consult ID   240              Unique Number   27.00

  Surname    Blackburn                   Agency

  SCI comment    Consultation by developers should be made on less than 30 proposed units.  It would appear that the valid opinions voiced by Parish Councils and expressed in the VDS and Parish Plans have very little weight in the process of resolving or granting planning permission!  It would assist the public if reasons were given for some decisions - particularly if the application is contentious.

  IWC Response   The comments on the threshold of 30 houses have been made by previous consultees and dealt with elsewhere in this schedule.  Reasons for decisions are now given on all planning applications and are recorded on www.iwight.com.