Shropshire Council planners have at last started the process of reviewing the authority’s Statement of Community Involvement (SCI), the document that sets out how the council’s planning department engages with local communities in a spirit of “community engagement” that is supposed to lay the foundations of what they persist in calling a ‘plan led system’.
It is in fact anything but!
If any proof were needed, the fact that Shropshire Council planning department have announced the START of consultation at the END of the extended Local Plan Review shows what our planners think of the SCI.
What they should have done was review the SCI through consultation and then restarted the consultation on the Local Plan Review. It’s not as if they didn’t know the SCI review was way overdue because enough of us were constantly reminding them!
Sent: 26 June 2019 12:25
To: Ian Kilby
Subject: SCI review
Good day Ian,
Are there any plans to review SC’s Statement of Community Involvement, the one adopted in 2011, seven years ago?
Amendment of regulation 10A
4. After regulation 10 (local plans and supplementary planning documents: additional matters to which regard is to be had) insert—
“Review of local development documents
10A.—(1) A local planning authority must review a local development document within the following time periods—
(a)in respect of a local plan, the review must be completed every five years, starting from the date of adoption of the local plan, in accordance with section 23 of the Act (adoption of local development documents);
(b) in respect of a statement of community involvement, the review must be completed every five years, starting from the date of adoption of the statement of community involvement, in accordance with section 23 of the Act.”.
By way of answer I got…
From: Ian Kilby
Sent: 26 June 2019 13:18
To: Dave Tremellen
Cc: Adrian Cooper
Subject: RE: SCI review
I think this is something we need to look at thank you for bringing it to my attention – I will review with Adrian on his return from leave.
Planning Services Manager
And I wasn’t alone in my concerns because someone else subsequently took up the matter of the SCI review with another principal planner (the same ‘Adrian’ referred to above), though in relation to a different matter…
Sent: 22 July 2019 11:36
To: Adrian Cooper
Subject: Re: Local Plan Review
I attended the scrutiny committee last Thursday and [s]omeone at that meeting pointed out to me that the Council’s Statement of Community Involvement, under a 2017 amendment to the T&CPA, is required to be reviewed every 5 years and hasn’t been. Is this right please?
With regard to the SCI, you are correct that the Town and Country Planning (Local Planning) (England) (Amendment) Regulations 2017 now require that a review of the SCI must be completed every five years, starting from the date of its adoption. In Shropshire’s case, the SCI was adopted in 2011 but was refreshed with minor amendments in 2014 (not taken to members for endorsement).
There is no question that the SCI is therefore due a review and work on this has already started, although progress to date has been frustrated by the demands of other work. I will let you know when we have an agreed timetable for the review process.
Adrian Cooper MA (Hons) MSc MSc MRTPI
Planning Policy & Strategy Manager, Economic Growth
Shropshire Council, Shirehall, Abbey Foregate, Shrewsbury SY2 6ND
Which obviously reminded Ian Kilby that I had still to be replied to because…
From: Ian Kilby
Sent: 30 July 2019 16:51
To: Dave Tremellen
Cc: Adrian Cooper
Subject: RE: SCI review
We are looking at it now
Well, it was an answer of sorts, even if it did beg the question as to why it’s taken them so long to get on with the review of a document that had, by the time of those exchanges, started to curl at its edges.
Best not to ask, I suppose. But some of us have been dying to ask the question about why the senior planning officers of Shropshire Council – and especially the portfolio holder who has responsibility for oversight of that department – don’t seem to take any notice of material they’ve produced at great expense, both in terms of money and time, in the not-so-distant past, “stuff” like “The Big Conversation”, just one of a long list of council initiatives that have subsequently sunk into obscurity.
There’s a whole shopping list of stuff just left sitting on shelves in a cupboard somewhere that Shropshire Council planning officers appear to be ignorant of, amongst others that rarely get a mention, the ‘Engagement Toolkit’ (2016) is worth a read:
Likewise the ‘Rural Toolkit’, which is set out in the Core Strategy (para 4.66)…
4.66 Shropshire Council is adopting a “bottom up” approach, whereby it works with communities at the parish and village level in together undertaking an intelligent analysis of the nature of their local community and how their village functions, and how it can be improved. This is done through an interactive toolkit that starts with the Parish Plan or Village or Town Design Statement where available; secondly adds statistics compiled by Shropshire Council, such as Census data, to provide a quantitative basis for discussion; and thirdly engages with the local community in a Community Testing Event to arrive at an agreed view of how the community regards its current sustainability. This methodology will provide quality evidence to help the planning authority make robust decisions on the designation of Community Hubs and Community Clusters. Undertaking the assessment does not commit a community to seek Community Hub or Community Cluster status. The approach is detailed further in the SAMDev DPD.
Hmmm. And that was for public consumption? No wonder it got quietly dropped.
Like much else it just paid lip-service to ‘bottom up engagement’.
And if you’re really up for it (might as well while you’re at it) a document that informs the wider argument for community engagement:
‘Engagement and the equality duty: A guide for public authorities England (and non-devolved public authorities in Scotland and Wales)’
OK, enough for now. Hopefully you’ll have started to get the point, which is simply that with so much ‘guidance’ out there, the generally accepted understanding of what’s meant by the word “consultation” should be clearly understood by even the dimmest of planning officers.
But of course, planning officers aren’t dim. By any measure they are clever enough to play semantic games with anyone, the rules of the game having been passed down through the ranks as part of their professional development.
Any one of those documents you will find cited to give legitimacy to Shropshire Council’s claim to be a local authority responsive to the concerns of its communities. Reading those documents and seeing how they are reflected in reality, however, in reality they do anything but!
Were it otherwise I’d be the happiest bunny around, but as it is the major issue is Shropshire Council planning department’s refusal to accept that the word “consultation” means what it says on the tin. Their choosing to maintain a permanent state of denial about engagement meaning an exchange of possibly opposing views until a negotiated agreement satisfying the needs of both sides is achieved, doesn’t redefine the word even when it’s accompanied by the planner’s death stare, finely honed in the course of their professional training and especially when dealing with those opposing their plans.
When it came out, much was made of ‘The Big Conversation’, it’s title said it all; as a statement of intent it takes some beating and opens by saying…
Shropshire Council recognises the need for customers, stakeholders and businesses to have greater opportunities and involvement in the democratic process and to provide an environment that supports and encourages social responsibility and action. Overall, we plan to develop a ‘together we can’ attitude, supporting collective social action, with our Councillors as active facilitators and enablers, best placed to listen to and advocate on behalf of those harder to reach in their communities. Engagement is broader and deeper than traditional consultation [my emphasis]. It’s about how we communicate with, involve, listen to, respond to and understand local people and stakeholders. How we help people by developing ongoing relationships with them to become active citizens who can discuss and influence the things that matter most to them.
You know, I get fed up with criticising Shropshire Council and at one time thought I’d sorted out my differences with its planning department, but changes in both personnel and attitudes have combined with changes in national legislation to systematically destroy whatever kindly thoughts had started to creep through since I passed a note to Ian Kilby that said: “I’ll try to be kinder”.
Ian was getting a fair bit of criticism from one of the committees I was a member of, and not from me I’ll point out, which in itself is a significant point worth noting because it shows I’m not alone, just the most vocal. It was about the slowness of the planning department to get back with answers to queries from councillors and Ian Kilby was explaining how difficult it was to recruit new planners, so many experienced ones having taken the opportunity to get out when the chance of voluntary redundancy was offered by a cash-strapped council. He had a point and that’s when I passed him the note – so heartfelt was his pleading.
And I have been patient or was until about five years ago when certain events made me realise that assurances I’d taken on trust later proved to be not just empty but deliberately misleading to shut me up until it was too late to do anything.
I suppose that reversion to character by the planners started in earnest when serious concerns about routing construction traffic through Victorian terraced housing, cars parked both sides of the narrow street, could have been overcome by agreeing a different route for the access to that new estate, a suggestion which was deferred by the principal planning officer “until such reserved matters can be considered”. Except that the application as it stood was subsequently waved through on the nod. No appeal because according to that principal planning officer a ‘consultation’ of sorts had happened. (You can read what you like into the fact that the planned estate was being developed by the council-owned housing company, Shropshire Towns & Rural Housing.)
To add insult to the injury of legitimate concerns being ignored, during that planning process my positive response – in the spirit of engaging in the process – to two requests for site meetings from one of the planning officers involved were completely ignored, no meetings took place despite my chasing them up. The formal complaint about that officer’s behaviour was subsequently dismissed as unreasonable on the grounds that she was overwhelmed with work.
There are increasing examples of the failure in community engagement in the consultation process coming to light as a result of the increasing reliance on electronic communication. It is a major weakness (although arguably an unintended consequence) that adds strength to Shropshire Council’s determination to remove a bothersome public from its affairs.
Put simply, if someone doesn’t have the technology they don’t have the information they need to make a judgement on whatever is out for “consultation”, which is why public meetings are important, and is why the current reliance on virtual ‘meetings’ simply doesn’t acknowledge the opportunity such a remote medium offers to a council already adept at dodging effective scrutiny.
The draft SCI at para 3.8 (Communicating Effectively) touches on this by mentioning lack of ‘Access, Skills, and Motivation’ but the only other method they mention has a touch of the disingenuous about it, printed material.
OK, except that in practice, since becoming a “paperless electronic local authority”, printed copies of reports can only be had by asking for them and establishing ‘need’, but not everyone knows to ask, let alone who to ask.
Final question. Is there such a thing as a virtuous vicious circle?