Author: Cyril Richert
Wandsworth Council has consulted on its draft Statement of Community Involvement (SCI), which is a document that describes how to get involved in planning decision-making process. The first Wandsworth SCI was adopted in 2007 and was last revised in 2012.
Comments were to be submitted before mid-December, and we have been a bit slow in producing a response. However, in view of our current efforts to get improvement in the planning process and our call for planning reform, we thought it was important to submit a detailed analysis of the draft paper.
You can read below the summary of our comment. To get more information, you can view/download the documents:
- Statement of Community Involvement 2018 draft for consultation
- CJAG Representation in response to consultation on the draft Statement of Community Involvement
- Clapham Junction Action Group: Draft Paper on Planning decision reforms
Statement of Community Involvement (SCI) draft for consultation
Throughout sections 1 & 2 we have considered that it describes community engagement for the full planning process (as stated in 1.1), and not only for the specific Local Plan review. We acknowledge that section 3 is specific to the Local Plan, but further sections detail also the current process for Localism (4) and Planning Applications (5).
If the SCI document intends only to the lifetime of this specific Local Plan review it should be clearly displayed at the top of the document.
The Clapham Junction Action Group (CJAG) is sharing years of frustration with many other community groups in the borough, caused by Wandsworth planning process. CJAG decided to participate to this consultation to emphasize our work on planning reform proposals currently discussed within local community groups in the borough. It seems therefore very inappropriate the display towards the end of the document (5.1, page 25) that “the Council has long-established and successful methods of dealing with, and consulting on planning applications”, methods which are actually the purpose of our reform proposals.
The Clapham Junction Action Group (CJAG) consider that the draft Statement of Community Involvement (SCI) is full of great principle but in practice contains no improvement to the issues currently discussed within the planning forum meetings and made public by CJAG.
Great display of principles in the document and no effect
In our views, the document highlights very positively the many benefits of “achieving effective community involvement in the planning process” saying page 4:
- more focus on the priorities identified by the community;
- ability to draw upon a local knowledge base;
- increased community commitment to the future of an area;
- and increased support for the Planning Service.
However, the paragraph 2.2 ends with the sentence: “This enables communities to have a better understanding of how planning policies are developed and how decisions are made”. That is exactly what was clearly criticised by members of local groups at the Planning Forum meeting 12 July 2017, which can be summarised by the claim: this is not a forum, this is an update meeting! Those frustrations have been expressed during previous meeting as well as by more formal emails to the PAC (Nov 2015). It is only recently that changes seem to happen, however not resulting yet in any change of policies.
Community groups have complained about the lack of consideration and wrote in an Open letter released in April 2014 that they cannot accept that “the valid objections made by residents can be ignored with impunity.” It seems far from the great principle of “more focus on the priorities identified by the community… etc”.
This is an obvious example of great display of principle in the document and little and no effect.
Wording should be strengthened to prevent ambiguity
As we criticised in the past, Wandsworth’s approach to planning is ambiguous at least and, as we saw in the past (the terms “likely to be inappropriate” used in the SSAD being translated in effect as “likely to be accepted”), wording should be strengthened and specified appropriately.
For example, the Council claims to take into account “the Gunning Principles”. However, “take into account” could be interpreted as “considered but dismissed”, as local community groups have claimed that it is often the case for public representations.
“Formative stage” is also very ambiguous if not misleading as 99% of developers will only consult at the final stage of the proposal, seeking recommendation from the officers and approval by the Council committee.
In a similar view, the structure of the sentence “demands of fairness are likely to be higher” is only a statement, without any consequence. It would be interesting to read the views of Wandsworth Council regarding a (quite recent) Supreme Court case in late 2014 involving Haringey London Borough Council and its consultation process. The judges said that consulting about a proposal does inevitably involve inviting and considering views about possible alternatives (especially on policies).
Great consideration for local groups, unfortunately undermined by reality
It is worth quoting fully part 2.4 of the section page 5, as we have rarely seen such acclamation of the role of local community groups.
Local communities are those that are most affected by development in their areas and who know the most about their neighbourhood. There are many benefits to involving local communities in considering planning applications for their area, as well as local plan making such as:
– detailed local knowledge, expertise and perspective of local people, organisations and community groups;
– greater understanding of, and support for local policies, strategies and decisions;
– community commitment to the future development of their area; and
– improving the quality of life, and of the built and natural environment of the Borough.
Following an Open letter sent by local community groups (Putney Society, Wandsworth Society, CJAG and Friends of Putney Common) to the Prime Minister on Wandsworth Council’s planning procedures and ‘localism’ practice failures, a Council spokesman said: “It is always regrettable therefore that [local community groups] have a more NIMBYist approach and choose to hurl false and groundless allegations around when they don’t get their own way.”
Therefore, in view of the section 2.4 of the draft SCI, we think that it is also important for Wandsworth Council to clarify whether local community groups know the most about their neighbourhood, have detailed knowledge and expertise on local issues, and as such are legitimate to work with the Council, or are just NIMBYs.
Except the description of intended process of consultation for specific purposes such as the Local Plan Review or the CIL funds, the document appears as a list of great principles (although most are still to be observed), with some generic aspirations, a dose of ambiguity and a lack of definition, without any specific commitment.
But in any case, Wandsworth Council should choose whether to consider that local communities are those “who know the most about their neighbourhood” with “expertise and perspective of local people” (2.4, p5), in which case the Council will seek to work on planning reforms along with Community groups – or whether the current “success” of the process, emphasized by the belief that the method are “robust and relevant” (5.1, p25) will aim to dismiss criticisms.
As CJAG aims to being proactive, we are including in Annexe our draft Paper on Planning Decision Reforms. This document has been shared for consultation within amenity societies and local groups since May 2018 and is being discussed within the Planning Forum since July 2018.