Warning, you are about to be frontloaded

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We have a light hearted addendum to our recent post.

As our previous post described, our attempts to make the case for equal rights of appeal continues to be dismissed by organisations who claim to have the public interest and the concerns of communities at heart. This is a bit perplexing for us so, in a (tongue in cheek) bid to better understand what’s going on, we’ve tried to have a think about what they’re actually asking of people.

One of their main arguments is that focusing on appeals will put too much attention on fighting it out at the end of the system when applications are decided, rather than encourage everyone to get involved earlier on in the making of plans such as the local development plan (This is called frontloaded engagement).

Our interpretation of what is expected is thus…

  • To start with as communities and individuals you must ignore any current concerns you have about development pressures or questionable development decisions going on in your area – it’s too late to influence these now and anyway it’s your own fault for not having got involved in local plan consultations five years before you moved to the area
  • through a process of collective voluntary amnesia, forget any previous negative associations you might have about planning, put on a smiley face and positive manner and get ready to dedicate a large portion of your life to learning new jargon, including several hundred acronyms (as far as we know medication for this is currently not available on the NHS)
  • be prepared to forgo any semblance of normal life while putting huge amounts of voluntary effort and time into learning acronyms, understanding the difference between MIRs and PACs etc etc.  Spend even more time becoming a quasi-planning body, learning how to consult your local community and gather the evidence and information required to develop your own local place plan, which may or may not have any influence over development decisions that impact on the life you used to have (you interrupted it some time ago, remember)
  • be prepared to work out exactly what a development plan is and to know, perhaps by osmosis, when and how to comment on it (because unlike the professionals you have not had years of training in acronyms nor are you paid to grapple with confusing websites and portals)
  • be prepared to be ‘frontloaded’ at what is in reality the middle of the development planning process where discussions and call for sites have already started with developers several months or possibly years ago. Be warned, it’s not entirely clear what will happen to you once you’ve been loaded. This is rumoured to be a potentially painful experience. There is no guarantee whether anyone will listen or care about anything you say once you’ve submitted to it. Read the small print carefully and be aware of the potential side effects on that life you used to have when you finally emerge out the rear end of the system.
  • constructively engage at the correct time and in the correct way without any guarantee of a response let alone of changing anything. Do not expect to have a chance to speak or challenge anything much when decisions are actually being made as this happens at the (business) end not the front of the process. And please do not complain if you miss the small window of opportunity open to you every 10 years, after all that is your fault.
  • continue to be constructive and positive when a ‘consensus’ on the development plan is reached in a process, the majority of which, you have mostly probably been excluded from even though you took the happy pills, did your best to learn the acronyms and subjected yourself to being frontloaded.
  • trust the whole process even when a development that is clearly out of line with the public interest and the development plan is approved thereby entirely undermining the one thing you gave up your life to try and achieve. Do not expect to be able to challenge this decision, after all you were frontloaded, so you’ve had your say. Resume what’s left of your life but take care coming off the medication, the acronyms may take a long time to leave your system.


This might seem a little facetious but we hope it helps to make a point. We don’t disagree with the principle of people being involved early on in the process, we just believe that to make it work communities need real power to scrutinise decisions. There are five main reasons for this:

  1. The planning system in Scotland is discretionary, decisions don’t need to follow what is agreed in plans. Calls to ‘frontload’ participation therefore invite people to get involved but not at the business end of the system when things actually get decided
  2. Early engagement has been promised for fifty years but has never been consistently realised. This suggests making it work properly requires a huge change in approach. Sadly this seems unlikely to come about without a significant increase in resources, skills and commitment on the part of local authorities.
  3. At the moment, it’s really hard to work out where the ‘front’ is. Getting the chance to comment on a draft plan long after work on it has begun does not really seem like being involved early in the process. Unfortunately that seems to be what the Scottish Government has in mind at the moment.
  4. It is plain wrong to argue that allowing people to appeal will lead to them not bothering to get involved earlier in the process. If appeals for both developers and communities were limited to departures from the plan then it would provide a powerful incentive for everyone to get involved and get it right earlier on in the process.
  5. Equal appeal rights would play an important part in ensuring subsequent decisions reflected the outcomes of early engagement, increasing public trust and making it worth getting involved even if that means being frontloaded!


We’ve yet to hear any meaningful response to these arguments from the self-styled guardians of the public interest which is a shame because we believe in planning and would like to work with them to create a system that really works for communities.


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Clare Symonds

Clare Symonds is the Chair of Planning Democracy.

3 Responses

  1. Avatar Gordon Bulloch says:

    A great blog post, Clare. It just reflects all the frustrations I have had with the development process within the Cairngorms National Park – and I had considerable experience of the planning process from my previous work. The Head of Planning for CNPA mischievously misrepresented so-called problems with objectors to planning applications at a Local Government & Communities Committee back in April – you might remember this.
    The other thing to remember is that the current Scottish Government doesn’t just ‘think’ it knows what is good for us – it ‘KNOWS’ what is good for us! Consultation is just a process for it to go through and then just do what it always wanted or intended to do.

  2. Avatar Clare Symonds says:

    Yes, we have had record numbers of emails and responses to this post which people identify with. Its not surprising as we based it on all the experiences people have shared with us. And yes I do remember campaigns in the Cairngorms being effectively dismissed as ‘folk who complain about everything’. Its a very good way of diverting attention onto the complainants rather than the issues they are complaining about.

  3. Avatar Lesley says:

    Yes, exactly! Very well put! It would seem that South Oxfordshire District Council have followed suit in their modus operandi- pretending to ‘consult ‘ and then going ahead with whatever they want regardless of the effect on local people, the environment or wildlife. I’m guessing that council doesn’t pay that well as they’re hardly attracting quality staff. This then begs the question: where does the money go? (The money WE pay in the form of council tax, not that which they keep moaning government has cut back on.)

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