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
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.
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.
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. |
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.