Reviewing the review

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To all those from the community sector who took time to respond to the planning review, brilliant effort. This blog reflects on how people responded to the review, what they said and how they said it.  Importantly it is clear that not only those that responded but many people (not just those who have been affected by planning) are concerned about the lack of influence over planning decisions and lack of equality in appeals. (Look out for some exciting survey results).


We hope you are all prepared for the next stage of Planning Bill preparation that will lead to all this consultation becoming law. It’s been a long haul we know, but this is really important.
We need you to help us out to get better community rights into the Bill.
Do get in touch, find out more about what you can do here or by writing to Daya. We have plans for a demonstration outside Parliament during the Bill. Come and join us.




As we wait for the Planning Bill to arrive in December ready for the parliamentary process of preparing legislation we take a deep breath to prepare ourselves for the final stages of this process.

We reflect on how the review process has been for those who took part.

And whether it was worth it.

One notable thing about the planning review process if nothing else is that it elicited an unusually large number of responses, particularly from the general public. The number of responses from ‘civil society’ actually increased during the long review process. I have collated this table to illustrate.

Figures on who responded to the written consultations

November 2015

Call for Written Evidence

April 2017

Places People and Planning

Civil society 163/ 41.7% 271 / 57.1%
Planners 111 / 28.3% 106 22.4%
Business 31 / 7.9 % 42 / 8.9%
Development industry 86 / 22% 55 / 11.6%
Total 391 474


I looked at a few other Government consultations to compare the numbers and it seems that the planning review has generated a significantly larger number of responses than a lot of other consultations, that I would assume are equally important and relevant to the public.
For example, the Child Poverty Bill elicited 116 responses in all, the community empowerment legislation had various consultations from asset transfer (82 responses) to community planning guidance (92) and the draft strategic police priorities (110 responses).

Altogether it could be said that it looks like a pretty comprehensive process of consultation took place which included working groups and oral evidence giving as well as written consultations.


As part of the review the Government also commissioned some research into the barriers to engagement in October 2016.  The public response to the study was significant, 1640 people responded to the online survey, most of these were from the public. These figures provide some confidence that what is being said is valid and should indicate that the public have a point to make and are keen to make it.


Unfortunately, there still persists an establishment attitude towards any member of the public who expresses their opinion or perspective on planning. Comments often being made that this is a ‘specific sector of society’ responding, people with a ‘special interest’ in planning, as if they have some sort of affliction.  But how would someone who has NOT had dealings with the planning system even begin to tackle this consultation?


We get really fed up with developers, planners and policy makers dismissing any community response as arguments from a minority group of society, who are frequently described as part of a selfish middle-class or NIMBY minority, that don’t reflect the views of broader society. It is often implied or stated that policy makers, developers and planners represent the “silent majority” as if there is some compliant public out there that agrees with everything that the ‘establishment’ say, these hundreds of people out there taking hours of their time responding to detailed questions are just a blip.


But perhaps it turns out that the views of this, allegedly silent majority, actually amplify those of these pesky NIMBY’s who are in fact providing a rather accurate portrayal of planning and are in fact representing a wide community perspective. Certainly the National Trusts recent survey of the general Scottish public concluded that

  • 60% felt they had no influence on planning decisions affecting their local area;
  • Only 41% of those surveyed felt their local historic environment has been protected or enhanced by the planning system.
  • Fewer than half (47%) felt that local greenspaces and natural heritage had been protected by the planning system.
  • Local communities’ priorities for protection and future improvement go much further than the current focus on enabling housing development – 49% prioritise outdoor areas, 47% housing, 46% public facilities and shops, 40% transport.


  • 90% want local communities to have the same rights of appeal in the planning system as enjoyed by developers, indicating dissatisfaction with the balance of power in the system at present.



And so exposed are subtly different standards of “representation” being required of different types of respondents. Community respondents somehow having a higher threshold to pass the ‘test’ of authenticity. There is no questioning of the veracity of industry evidence or any caveats to point out that theirs may not be entirely unbiased views? The public with their social and environmental concerns expressed in non monetary terms, are easily ignored in the current world of policy making.


And yet how stupid do those who took Trump’s inflated claims of bringing economic development to Aberdeenshire look now as he breaks all his investment promises?


Personally, I think this pervasive attitude is pretty reprehensible considering the sheer effort that people have gone to, to provide clear evidence of their experience of the failures of planning, particularly in the earlier stages of the review when the questions were more open and allowed greater expression of views.
As an aside I found the ways that different people have gone about their responses really interesting.


It would make a great thesis for a student.


Some respondents (and I refer to those writing as individuals or community councils or from a community perspective) write quite detailed accounts of their own experiences of the planning system such as Dunblane Community Council’s extremely articulate and constructive response that not only describes their experiences but seeks to illustrate clearly what works and what they want changed. Other individuals have included details of surveys that they have conducted to highlight what they see as the problems, such as the differing approach from local authorities on publishing representations online and allowing the public the right to speak at hearings.


Others such as some Aberdeen residents provided photographic evidence to try to illustrate just how baffling the decisions made about their city centre have been.
CASE STUDY: Take the example of Marischal Square, Broad Street, Aberdeen:

Following extensive public responses to the PAC, this is what the public said that they wanted

This is what Aviva Investors and Muse Development are providing in a joint venture with Aberdeen City Council


Particularly in the later stages of the review you can detect a good dose of cynicism for the whole charade and what it will achieve in a number of the responses and yet people have still gone on to write detailed studies of their experiences. Quite a number clearly feel frustrated by the nature of the questions in the Places, People and Planning consultation, which are formulated in such a way that they don’t allow people to express their real concerns.

Significant concerns and criticism around the purpose of the review were raised by some individual participants within the group of civil society, notably around the framing scope & questions” (Review analysis, Kevin Murray Associates)


Or as one respondent put it

the questions we are being asked to answer are overly constraining because they are couched within a basic acceptance of the adequacy of current arrangements and notions of “efficiency” calculated in terms of short term financial, rather than long term community, costs and criteria.”


Another respondent rather more candidly expressed their complete lack of confidence in the consultation process

I’ve been ignored by so many of the planning-type people I’ve contacted; or they clearly haven’t even bothered to read what I’ve written, so I’m not going to spend too much time on this


The thing is that despite all this effort, this collective community endeavour, this plethora of information, individual and group knowledge and experience is ….lost.


Very little of it has been translated into the final proposals. How have the many deep seated concerns been addressed? Certainly the distrust and lack of confidence was clearly stated in the Barriers to Engagement Research

The report is forthright in acknowledging that, from all perspectives:

there is a serious lack of trust, respect and confidence in the system, and that community engagement exerts very little influence on planning outcomes.


But how has this fundamental problem been addressed?


It has not.


For nowhere in the Government’s proposals for change, that will be legislated for in the upcoming planning bill is the extent of the problem realised.


What reassurance does it give communities that things will be done better? What rights have they gained from this process.




What measures have been taken that their input into planning will be listened to in future? That community engagement will be done better? Nothing.


Because fundamentally the status quo has been maintained. Communities lose out for the second time to the volume house builders and developer lobbies.


So, to the public, the ‘civil society’ who did bother to respond to any part of the consultation we would like to take this opportunity to thank you. It was a mammoth task to respond to all the research, evidence gathering and consultation responses that this review set you as homework. Well done to the hundreds of you who bothered, for the hours of time you took away from work, family and friends to read through the many complex documents, to fill in the time-consuming surveys and decipher the impenetrable jargon. Thanks to those lay people who spent hours trying to understand the difference between an LDP, an SDP, an MIR, the NPF, a PAC and an SPZ, trying to ascertain the implications of losing them, bolstering them, lengthening them and increasing their number and scope. Thanks to you who tried so hard to explain in your own way.


Hopefully it won’t put you off engaging again in the future, because there are many voluntary hours yet to be spent dealing with planning related stuff. After all if Local Place Plans are introduced there are hours, weeks, months, no actually it will probably be years of work to be done working out  how to produce one, to pour over documents, decide boundaries, consult your own communities and decide the details of what will go in. No doubt the result will be pretty much the same as your efforts to engage in this consultation, it will be an awful lot of effort for very little return. Because it is in the interests of developers and the alliances made between those with vested interests to maintain the status quo.


Unless of course there is someone out there who really is listening. Perhaps some of our elected representatives might help us to address this during the various stages of the Bill.


It’s not too late, you can still hope that the political process will provide a better Bill. We can still demonstrate how important this is and demonstrating is what we will be doing. We are not giving up. We hope all those taking part in the consultation won’t be too. And those who couldn’t summon the energy.


So we ask you to help us by contacting MSP’s before and during the Bill stages. The more people doing this the more likely something will happen. But we need people power.


We need everyone who responded to the review and more to take a deep breath and go for it one more time.


People power works.


Politicians still respond to their voters


Some still believe in giving the community a voice!


Get in touch with them


Anyone wanting more information of how they should do this, please get in touch.


Lots of you have already. More of you need to.


We have postcards you can send to them. Go to our Equal Rights of Appeal page to order some. Get them sent!

Go for it!

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