The consultation deadline for the Places, People and Planning Consultation has now passed. Many of you we know have responded. Here is our response , all 25 pages of it!
And a blog from Daya
Here we are as I write this – in the last day of the Planning Review consultation and many people and groups have spent this sunny weekend honing their responses, including us at Planning Democracy. The whole review period has been extremely busy time for everybody and as part of my involvement I would like to reflect on the process just witnessed.
When I joined PD last year one of my first tasks was to read the responses to the initial Planning Review’s Panel’s Consultation submitted on Scottish Government website. Unbelievably I somehow managed to work my way through about four hundred responses of various length and level of detail. It took many hours but it gave me an interesting insight into the different perspectives from civil society, the development industry and planning professionals. My background is in community work and with my new post as a network officer, my interest lay in the empowerment of communities as well as to the responses relating to Equal Rights of Appeal.
The overall feeling I had from the community responses was that the current early engagement wasn’t working for people and there needs to be a radical change to improve public trust in the planning system. It goes without saying that equalising appeal rights would go a long way to achieve that.
Every month we receive enquiries by email and phone, these are really challenging to deal with, not least because of the huge range of issues from demolition orders to legal challenges, enforcement notices on dormer windows to housing in greenbelt, unauthorised work to listed buildings, procedural advice on PLI’s and community council and council officer behaviour, and not least threats to woodland and places of outstanding natural beauty, and loss of parks and open spaces – the list is endless.
Often these inquiries are accompanied by messages from people saying they are losing the will to live and how hard it is to get involved in planning in general but especially with the added burden of the current consultation. People tell us they spend days reading and writing, often the planning portal is not working, and the questions being asked of them are difficult to comprehend, “it’s like having an exam like with lots of background knowledge required, like doing PhD”. One person told us they would rather give birth again as it is quicker, easier and less painful than responding to a planning related issue.
But in addition to the inquiries I had to deal with the planning review was now in full swing. It became clear that people were not aware of what was going, or needed more information, so we decided to hold some workshops. Over the next few months Planning Democracy held 10 events across Scotland. Our purpose was to try to highlight the review and its importance, how people could respond and what issues to concentrate on. We also wanted to hear from as many people as possible to inform our own response.
We visited various communities, from the two biggest cities to the smaller and rural places, from West Kilbride to Aberdeen and a fair few in-between, including a Cairngorms National Park area. One night we had a double booking with one event in Edinburgh and another in East Lothian. Luckily Malcolm had just started as our newest Board member so in true PD style he was roped in to helping. Despite all the issues with running two events in one night for a small organisation like us, (like who gets to use the projector!!) both events were successful, the one in East Lothian proving so popular that people were queueing out the door.
These events were organised by PD supporters, community development trusts, conservation groups or community councils who wanted to find out more about planning in general and who wanted guidance on the review. People turned up in all sorts of weather and even on Friday nights; they were keen to explore how they can engage with the planning system and how this review will address the issues they face in their communities.
It was great fun meeting everyone, each venue was very different, each event had its own tone and feel. Some people invited their local MSPs to chair or attend while others were attended by local Councillors and even local authority officers. Venues ranged from churches and community halls to town houses and city chambers. The Glasgow meeting was held in a biker’s venue Soulriders, hosted by Pollokshields Development Trust and arranged by me from my hospital bed while I was in having an operation. It took a fair few buses, trains and automobiles to get to them all, including a 160-mile round trip to West Coast which ended in me getting hopelessly lost in an industrial zone somewhere in the middle of the night thanks to a badly signposted M8 diversion.
Despite some of the challenges some very inspiring things came out of the workshops, in particular in Midlothian, East Lothian and Aberdeen/shire where community councils are all getting together to share learning and knowledge. The Midlothian Federation of Community Councils have been working together, with the better and less well resourced communities coming regularly together to share experiences, inviting council representatives along and being as inclusive as possible.
The two Lothian events attracted possibly the most varied attendance, with community councils, development trusts and individuals all meeting up. The great result was that now the East Lothian Association of Community Councils and Midlothian Federation of CCs have established a link and are looking forward to working together. As neighbouring areas they have much to share. Also, following the Aberdeen meeting the planning committees of different CCs are now getting together on a regular basis and sharing knowledge. This is exactly what the Planning Democracy Community Network is designed to do, to get people together for support and solidarity. We are still in the early stages, but it is clear there is much to be gained from these collective, inclusive meetings.
The issues raised at the events had individuality as well as common strands. Common themes included the difficulties of understanding the planning system, communities feeling consistently ignored, housing (namely high numbers, wrong type and poor quality), inadequate regulation of developers, lack of transparency in decision making, lack of resources for planning and community engagement, need for stricter enforcement, repeat applications and the overall lack of attention to environmental matters which people really care about.
There were many concerns regarding very specific issues which varied between different local authorities like distinct National Park ‘proofing’ and a plague of retrospective planning applications in Cairngorms, lack of enforcement and developer’s trumping community plans in Glasgow, Local Review Body decisions causing a headache in Midlothian, an oil rig decommissioning plant with apparently no Environmental Impact Assessment or consultation is worrying North Ayrshire folk, privatisation of public space and problematic Section 75 agreements in Aberdeen to name just a few.
There were some memorable comments, one came from a retired planner reflecting on his education in the 70s when he was trained to be a public servant, he felt that this is no longer the case anymore with the emphasis being on delivery of economic development more than making places special. The belief that planning is not in public interest any more was echoed from elsewhere, some people said that “the council officials now sound more like developers than civil servants” and “the planning system continues to facilitate speculative money-making without delivering socially useful development”. It is important that our own response amplifies the most consistent messages to come out of these workshops namely that communities don’t need increased involvement and gimmicks, they want their already considerable input to be acknowledged, listened to and respected. So many of the individuals and groups we met noted the expertise gap as a major problem that requires a very ‘steep learning curve’ and often leads to large amounts of wasted effort being spent pouring over legal or technical details, particularly in relation to this review. They want the review to acknowledge the existing power imbalances and to address these considerable inequalities, including of course an Equal Right of Appeal. But many are cynical and do not hold their breath!
Perhaps not surprising when many took part in the Barriers to Engagement Research, but where are the results? Have they been published before the consultation? Have they informed the proposals? Its like tumbleweed. It is easy to conclude that the message coming from the 1900 people who responded is a little too inconvenient for the review team. Perhaps a few too many people were asking for ERA? It was notable and pretty unsubtle that in the online consultation how question 15 had been carefully edited to stop people answering the direct question “should current appeal and review arrangements be revised?”
We hope that our workshops helped some people, we tried to make it a bit less agonising for people to engage in the review and hope that our community guide may have helped them navigate their way through the 34 questions of the response. Well it’s all over now and good luck to the person who has to make sense of all the responses. Our message coming from people all over Scotland to the Scottish Government is to please listen and take note of what people are saying. People collectively have spent probably the equivalent of several months responding, Planning Democracy alone have spent 8 days tackling this particular response . The least those setting us such an enormous exam like consultation can do is to respond and address the issues.
What do we want? Fundamental change that addresses inequalities.
When do we want it? Before we die of consultation fatigue!