Currently, local authorities are legally required to consult at two points before they submit their draft plans for examination: the initial Regulation 18 stage and the later Regulation 19 phase, prior to the Local Plan being sent to the Planning Inspectorate for examination. Under the proposals within the White Paper, Local Plan preparation would be subject to a strict statutory timetable, with ‘meaningful public engagement’ at two points in the process.
Consultation on a non-statutory planning application would ‘streamlined’ (reduced) on that basis that it ‘adds delay to the process and allows a small minority of voices, some from the local area and often some not, to shape outcomes’. Instead decisions on planning applications, in most cases, would be delegated to planning officers rather than considered by a committee.
The principle of ‘zoning’ as outlined in the White Paper is already used extensively in the US, Canada, China and elsewhere in Europe. Some respondents felt that its introduction would be beneficial:
The uncertainly over UK planning applications is very complex compared to most countries. Chinese investors are always very surprised by our planning system as they are accustomed to knowing what the parameters are. In UK its so much more subjective. With more clarity through strategic planning, you could remedy many of the issues faced at a local level.
Planning consultant
But consultation lacks visibility, and it seems to me that consulting at a strategic level, rather than on specific planning applications, will only add to that.
To increase awareness and understanding – whether in consultation on a planning application or a Local Plan – more clarity and purpose is required. We must cease to (be seen to be) consulting for the sake of consulting. Each consultation must have very clear objectives which are made clear to local residents in the form of a consultation mandate.
A hotel developer interviewed felt developers’ consultation would benefit from better communication with local authorities – not solely the planning departments, but with officers working within stakeholder engagement, health and other departments.
Another developer felt that less consultation (limited to an online questionnaire) would be beneficial, because ultimately the local authority then consults on the same scheme. This chimes with the essence of the Planning White Paper – though the Committee’s report differs on this point.
However, the majority of interviewees disagreed with this sentiment, seeing consultation as an opportunity to iron out any issues that might result in refusal, resubmission or appeal. They, like the Committee, felt that consultation at a development level is still required.
And although the Planning White Paper aspires to more effective consultation at a strategic level, there is much scepticism about whether this can be achieved. In an open letter to the Government in October last year, 14 London planning authorities slated the document as ‘unworkable’ and ‘a threat to local democracy’. Focussing consultation on strategic planning, the authorities said, would offer landowners and developers a ‘fast-tracked route’ to planning consent but at a cost to local communities. Instead, it says, ‘We should be putting communities at the heart of place making, increasing the resources of our planning system and strengthening local democracy’.
Most developers and planning consultants interviewed as part of this research felt that the proposals within Planning White Paper wouldn’t – or shouldn’t – materialise. They felt that strategic planning is too remote to compel local residents to take part, and that already-stretched local authorities lacked the resources to run effective consultations.
I struggle to see how we’re going to get local people involved in something that may or may not happen, over such a long term.
Planning consultant
Interviewees were also concerned about the risk of not consulting and the community relations issues that this could pose. Consultation is not simply a hoop to jump through. It has a valuable role in shaping a planning application, creating a scheme suitable for the specific location and mitigating the risk of refusal or appeal. It’s reassuring that many developers and planning consultants share this view, and I hope that the Government will take this into account when drafting the imminent Planning Bill.
There are strong arguments in favour of consulting at an early stage (ie, on Local Plans):
Arguments advanced in favour of the changes were that they would reduce public disappointment at applications being overridden on appeal because of existing Local Plans, cause the system to work more efficiently by reducing political interventions that prioritise local resistance to development, and enable proper discussion of the trade-offs “rather than playing whack-a-mole with residents’ objections.”
But consultation should continue at a planning application level:
We support enhancing public involvement with Local Plans. However, figures cited by the Minister suggest that far more people are involved at the point when individual planning applications are considered than at the Local Plan stage, and this was backed up by the evidence. We also fear that people will resort to legal measures if they cannot comment upon and therefore influence an individual planning proposal. Therefore, all individuals must still be able to comment and influence upon all individual planning proposals.
This is because people are more likely to engage on planning applications than on strategic planning:
North Northamptonshire District Council stated that: Typically, on our plans, you will get in the low hundreds of people involved in the plan-making process who make formal representations, whereas, when it comes to the planning application, you can easily have thousands of representations on a controversial application. That is notwithstanding that those same sites—I have some in mind—were part of the local plans that have been subject to a process, but people really only engage when there is the immediacy of a planning application.
Numerous submissions argued that individuals mainly became involved in individual planning decisions rather than at the Local Plan stage. We were told that people’s interest in planning issues results from nearby development. This was because it is inevitable people are often more motivated to give up their time to engage on individual schemes where they can see a direct impact upon them [rather] than on plans which may influence development in years to come.
The proposals within the Planning White Paper (ie, to introduce zoning) threaten people’s involvement in planning:
The Government’s proposals could potentially impact on public involvement in a significant way.
The majority of our evidence thought that the proposals were likely to reduce public involvement. This would chiefly be through abolishing the ability of people to comment on individual planning applications in growth areas and other extensions to permission in principle.
The scale of the change being proposed was laid out by the RTPI: It is still an enormous challenge to overturn 70 years of people’s expectations that they can be involved in individual planning decisions. At the very least, it will require a national campaign of education plus significant extra resources for community engagement at local level.
The problem with consultation on planning applications is that people will always want to debate the principle of development – despite this having already been agreed through the Local Plan process:
Community engagement at the local plan stage should be a basis to move plans forward, with local consent. However, further community engagement when more detailed plans are brought forward can confuse a process when they fall back on the fundamental principle of a development. Instead, community engagement at the design stage should identify and address specific issues around homes that will be delivered for local communities.
It is important not to relinquish the role of people in planning:
A crucial element of the planning system is the involvement of members of the public. Whether that is putting in a planning application, responding positively or negatively to another’s application, or contributing to a Local Plan, this has been a mainstay of the system since 1947.
That’s despite the fact that many sections of society are disenfranchised by the current system:
The Government’s view that participation was skewed towards particular groups, with younger people less likely to participate, also had some support.
Priced Out argued that young people were failed and local campaign groups, disproportionately made up of older and homeowning residents, dominated the system.
Save Greater Manchester Green Belt complained that: Participation in planning currently doesn’t feel like it is accessible to all. The systems are complex, and the language and systems seem to be from a bygone age. The White Paper is just adding to this inequality by not including the community at an early stage of participation. People with money, education, access, and time can navigate the system making it inequitable.
But this isn’t necessary a reason to change the current system:
The Department of Urban Studies and Planning, University of Sheffield stated that: There are significant dangers in justifying reductions in opportunities to participate on this basis. The dominance of unrepresentative minorities in public and democratic life is certainly not restricted to the planning process and would not be accepted as a reason to abandon democracy in other spheres. Rather it should be understood as a reason to deepen and extend engagement amongst under-represented groups.
A problem with the current system is that planning decisions frequently ignore consultation:
The sense that planning proposals are agreed to despite local objections was frequently voiced in our survey.
Ironically, if the changes proposed in the Planning White Paper were put in place, planning applications may continue as before anyway:
Claire Dutch, a planning lawyer, emphasised that planning appeals would continue, as developers would proceed through the standard planning process when they thought the Local Plan’s requirements would not permit them the necessary “density, height, scale, massing, et cetera” in their proposals.
THE COMMITTEE’S VIEW ON THE USE OF DIGITAL TECHNOLOGIES
Generally, methodologies used need updating:
The overwhelming majority of our evidence voiced criticisms of the current state of technology in the planning system. The Home Builders Federation described the current situation as “antiquated processes to engage the public.”
The Institute of Historic Building Conservation stated: “There is scope to utilise more digital technology in planning.”
In some circumstances electronic mapping is already being used effectively:
We were informed that parts of the current system do already make use of electronic and digital tools in plan-making, decision-making, and in sharing information about applications. There was praise for email notifications about applications on a street-level basis, and the use of virtual planning committee meetings introduced during the COVID-19 pandemic. It was noted those with care responsibilities and mobility problem had been able to participate.
There is a need for more digital mapping:
It was thought likely to increase the involvement of younger people in the process, addressing their lower engagement at present, alongside retailers and prospective homeowners.
It was also thought likely to increase the pace and efficiency of the system.
There was support for the better collection of data with a creation of national data standards and templates; and for 3D maps.
We were told information gathered through the planning system could help with building safety through fostering a golden thread of building information, and that digital technology could facilitate planning across local authorities.
London was cited as an example of good practice that others aspired to. There social media has helped to bolster engagement, there is more open data available in a public format and on a single website, different 3D models are available, and data on strategic house land available can be collected live rather than through a rolling programme.
We propose the use of virtual participation in planning meetings continue alongside in-person meetings after the COVID-19 restrictions have been lifted.
But there remains a need for traditional, offline, consultation methods:
However the CPRE did note that even more people would have been engaged had meetings been recorded; and that the virtual format removed the opportunity for informal conversations with participants, leading to a rather stale format rather than constructive conversation.
We welcome the greater use of digital technology in the planning system. But we recognise the need to ensure those lacking access can know about and participate in the planning process.
The general support for enhanced technology was coupled with wanting a continuation of existing, non-digital methods of communication.
We were told that surveys had found 5.3 million people adults in the UK had not accessed the internet in the preceding three months, that 9 million people in the UK struggle to use the internet independently, and that 11.9 million people lack the digital skills needed to go online. The changes might adversely affect people living in rural areas (because of a less reliable connection to broadband), the elderly, the poor, those in manual occupations, those without English as a first language, disabled people, and Gypsy and Traveller communities.
It was suggested, drawing on experience from neighbourhood plans, that IT was often the less successful way of engaging local people.
The poor record of central government in delivering IT solutions was also emphasised.
There were calls for the preservation of existing methods of advertising planning applications and Local Plan consultations through signs on lampposts, walk in ‘town hall’ events, face to face engagement (e.g. through workshops), hard copy documentation, and notices in local newspapers. We were told that this helped to ‘push’ information to the public.
The Minister suggested that the existing statutory notices on local newspapers and on lampposts would become a matter of discretion for local authorities. We do not agree with this approach. It risks creating a postcode lottery as to whether such notices continue. This would disadvantage those residing in financially stretched councils and those moving into local authorities where such practices have been discontinued. The existing statutory notices should be retained for all local authorities, to be used alongside technology.
Citizens’ assemblies provide an opportunity for better consultation:
Several submissions suggested that citizens assemblies might have a role to play in planning.
They were particularly recommended as a means to draw in hitherto under-represented members of a community.
The CPRE saw it as a way to reduce the adversarial culture of planning.
THE LEGAL IMPLICATIONS
All consultation, if part of a Local Plan, will be potentially subject to judicial review in a way that is not currently the case with non-statutory consultations on developer planning applications:
Claire Dutch, a planning lawyer, told us that there was likely to be an initial flurry of judicial reviews. She expected once the system was established there would be fewer judicial reviews, but they would be directed against Local Plans. This, she warned, would be “more debilitating” because a successful review “can stop it [the Local Plan] in its tracks and stymie development generally in that area … The JRs [judicial reviews] against plans does worry me.”
FINALLY, SOME STATISTICS ON ENGAGEMENT IN PLANNING
26% of people claim to have responded to a Local Plan (YouGov)
8% 16–18 year olds stated that they had been involved in a survey about the future of their neighbourhood run by their local council or a property developer (Grosvenor)
44% of people surveyed had engaged with the planning system – eg, searched the council register for permissions in their local area, submitted, objected to or supported a planning application, campaigned to stop a development, or spoke at a committee or meeting about planning applications. (Opinium for Demos)
Those over 55 were most likely to have engaged in a planning consultation (50% said they had), whilst 34–54-year olds had the lowest rate of involvement (43%). (Opinium for Demos)
Homeowners, residents in London were more likely than renters and residents outside of London to have been involved (Opinium for Demos)
These figures contrast strongly to information given to the Committee by the Minister, that 3% and 1% of the public were involved in individual planning proposals and in Local Plan formation respectively (Figures originated from an article published by the RTPI)
What is the point in public consultation – unless you know what you should be consulting on?
Articles on consultation in planning frequently focus on the methodologies used (online versus offline) and the potential to reach wide-ranging stakeholders (the ‘hard to reach’ or ‘seldom heard’).
But perhaps more importantly – or at least an important initial consideration – is what is consulted upon. Do consultations work best when the community is asked very focused questions to shape the planning application? Or should people be given a blank sheet of paper on which to offer a wide range of thoughts and suggestions?
To what extent is this affected by location, sector, demographic and other variables? Should the approach be determined by the timing of the consultation in the planning schedule – more general earlier on, more focused as the submission date approaches?
My ebook, Considering Consultation Content, the first in a series entitled People in Planning published by the consultation specialist Bang the Table, addresses all these questions and more.
People and planning are inseparable: planning exists to create well-functioning spaces for people, to enable social, economic and environmental priorities to shape places and to protect the natural and cultural heritage for future generations. As such planning is intrinsically linked to individuals’ homes, sense of place and local identity – and consultation, as the means by which we communicate with people on planning issues, is imperative in maintaining good public relations.
Because people are intrinsic to planning, the profession involves people at every stage. Yet planning is essentially about delivering change, and change is rarely popular. There is also a need to balance complex social and political concerns, and to facilitate mutually beneficial coalitions between stakeholders. Communications in planning, therefore, is challenging.
There are a variety of ways in which people can be involved in the planning process. Community involvement or community engagement are the terms most commonly used to describe ongoing, informal communication between a developer and a community, while consultation refers to the more specific process of involving a community in shaping proposals or seeking feedback on specific proposals.
Consultation – which takes place at several stages throughout the planning process, from national government level in forming Planning Policy Statements and strategic planning, through to neighbourhood planning and development control – is described by The Consultation Institute as, ‘The dynamic process of dialogue between individuals or groups, based upon a genuine exchange of views, with the objective of influencing decisions policies or programmes of action’.
As a people-orientated process, planning (and consultation specifically) is not immune from the human characteristics of influence, bias, self-interest and political interference.
The notion that community involvement can benefit planning decisions is unequivocal.
Communication regarding a proposed planning application is usually the first point of contact that a developer has with the local residents likely to be impacted by its proposals. As such it is a very important first step in public relations – both in terms of reputation management and community relations. Run well, a consultation can establish lasting relationships with a local community that will reap wide-ranging benefits throughout the construction and marketing stages and beyond. But if done half-heartedly, consultation will attract criticisms of ‘tokensim’ and ‘sham’: a significant blow to an otherwise untarnished reputation.
When a pre-planning consultation over and planning consent won, a significant amount of community engagement is complete. But as the new scheme moves into the construction phase, community engagement too enters a new phase.
A successful pre-planning consultation will have created a good foundation for the next stage of engagement. But rather than a continuation of the work to date, community engagement post-planning has new aims and objectives, new stakeholders and new challenges. The development team will change with the addition of contractors and perhaps the omission of the planning consultant; new teams within the local authority will have an interest and the local dynamic will metamorphose as residents / users of the new development emerge. A proactive approach towards community relations is required to ensure a constructive relationship between all parties.
A Construction Management Plan (CMP) is a set of conditions put in place by the local authority to ensure that developers minimise the negative impact of construction on the surrounding community. A CMP typically includes restrictions on working hours, vehicle movement and access, parking and loading arrangements, parking bay suspension, temporary traffic management orders, the impact of scaffolding on public highways, the height and aesthetics of hoardings, how pedestrian and cyclist safety will be maintained, control of dirt and dust, waste management and communication with local business and residents. Planning consent rests on the CMP and if the developer fails to comply with the CMP, development can be halted. Therefore it is vitally important that developer upholds the CMP. For larger projects, an individual is often put in place to oversee liaison between the developer and the community, to ensure smooth communication where possible and to gain an understanding of any problems that might arise.
Good community relations can also protect and enhance the reputation of the developer and other members of the project team. Without fear of generalising it can be said that the process of construction is rarely popular. The imposition of a highway across previously unspoilt countryside, the doubling of a small town with a new housing estate, or the construction of a power facility: few changes to the physical landscape are welcomed. Where negative sentiment already exists within a local community, the developer has an uphill struggle to deliver the project while maintaining a good reputation. And once work begins, that reputation can be further tarnished due to frequent movements by construction vehicles, the noise of pile driving, road closures, parking cessations, occasional cuts to power supplies and numerous other, often unpredictable, consequences of construction. Managed badly, this can lead to protests, negative media coverage and a torrent of criticism online. So the challenge to protect the development team’s reputation is a complex one, applying both at a corporate and a local level.
If managed well, good community relations is a substantial investment in the end product. The first residents of a new housing development, if appreciative of the development team, can become ambassadors for the scheme and benefit sales. A business district which maintains a positive relationship with tenants despite construction work will attract tenants. And a clean and accessible shopping centre is a popular one.
A good relationship with the local community will not only enable the development team to minimise disruption where possible, but also to pre-empt any future problems: regular dialogue with residents can identify problems before they occur and avoid, rather than mitigate their affects.
In countries such as the UK (which has eighty-nine percent digital saturation), online communication is increasingly used in public participation because of its accessibility: its ability to reach people at all times, with immediacy, through a variety of means: its ability to overcome language restrictions, access ‘hard to reach’ groups (particularly commuters, families with young children, the elderly and disabled) and break down social hierarchies. Features such as voice recognition, directional controllers, use of screen readers, ensuring that websites are compatible with speech recognition software and providing ‘translations’ of complex technical documents can potentially address specific accessibility issues.
Technological change impacts on the amount of information in circulation, the speed with which it travels and the potential for a message to spread. Online, a ‘level playing field’ reduces hierarchies: communication can be on a one-to-one, one-to-many and many-to-many basis and the ‘filter’ of traditional media is removed. Sophisticated communications tactics can allow for the formation of ideas or concepts, a more iterative approach, more responsive dialogue and a greater flexibility. Furthermore, new methodology enables efficient and extensive analysis.
The American University Center for Social Media identified internet usage as falling into five categories: choice, conversation, curation, creation, collaboration. In a planning context, these behaviours might be described as follows:
Choice: finding information on strategic planning, policies and planning applications though search engines, recommendations (on or off line), news feeds and niche sites.
Conversation: entering into debates on discussion forums, blogs and microblogs, taking discussions into new forums by sharing links and mobilising action.
Curation: selecting and drawing together information on blogs to form powerful arguments, carefully targeted to specific groups; posting and reposting views and suggestions and sharing links.
Creation: posting brand new multimedia content, including text, images, audio and video.
Collaboration: creating groups of support or opposition for the purposes of campaigning both online and offline.
Writing about change in methodology for my first book in 2016, I identified that online consultation fell into three categories: via social media (primarily Facebook, Twitter and YouTube); using ‘off the shelf’ consultation websites (Citizen Space, Bang the Table), and through bespoke consultation websites (either produced in-house or using an adaptable template website such as ConsultOnline, possibly with additional third-party plugins and widgets such as Sticky World embedded). In just four years, the selection of dialogue methods available has proliferated to the extent that there are now infinite categories.
Consultation websites are no longer single dialogue methods. ConsultOnline, for example, provides a range of tactics including polls, forums, infographics, videos, blogs, vlogs, blog posts and podcasts which offer immediate and very effective means of analysis. Data collected both online and offline can be processed via the online platform, thus creating a consultation report instantaneously.
In addition to websites, consultation apps are now increasingly used in consultation.
Give-My-View, created by Built-ID, is a web-based platform which encourages collaboration data-sharing. It connects development teams and local communities through a visually appealing and highly accessible website app and enables a development team to guide and educate the community as a project evolves. An interactive timeline manages expectations while a newsfeed enables the development team to counteract the spread of misinformation. Other features include polls, questionnaires, and ‘quick facts’ which provide information in relation to specific questions. Geofencing (the use of GPS technology to create a virtual geographic boundary) provides the ability to restrict online interaction to a specific geographical areas. To encourage use among younger audiences and simultaneously benefit relationships between the developer and the community, the app provides the opportunity to earn points in return for engaging and sharing. Points translate into money for a selection of local charities. Community members are able to browse ‘influenced decisions’ from previous phases which assists in building trust between the developer and the community.
The principles of gaming are increasingly incorporated into public participation. A consultation carried out by the University of Dundee’s Centre for Environmental Change and Human Resilience successfully attracted young people to planning through the use of the popular game, Minecraft. A youth camp was held at the University, where secondary school pupils worked together to develop hypothetical visions for the Dundee waterfront through interactive sessions using Minecraft. Each participating school team was given an individual plot on a model of the Dundee waterfront and encouraged to develop a vision. At the end of the day, a winning team was presented with a Future Planner Award. A central aim of the Youth Camp was to encourage young people to think differently about their communities and to help them understand their potential to influence change. Minecraft classroom edition enables pupils to work as a team and engage in a co-production of knowledge in the design of shared spaces.
CHLOE (Conceptual Hexagonal Land Use Overlay Engine) is an online mapping and reporting tool developed by David Lock Associates to enhance engagement and improve information capture during community and stakeholder workshops. In small groups, participants are encouraged to create conceptual masterplans for potential growth locations by populating an empty grid, tile-by-tile, with a selection of land uses. An aerial photo overlaid with local constraints helps to inform the group’s discussion on where development can and cannot be placed. As development tiles are added to the grid, CHLOE feeds back live alerts to guide the group through the design process, allowing them to make informed decisions. Adjustable parameters, including residential densities, are combined with open space standards and demographic data (specific to each local authority) to highlight the impact that housing has on associated land use composition. Different scenarios, based on changes to the parameters, can be tested, recorded and compared. CHLOE has proved extremely successful in enabling stakeholders to discuss and consider development that is appropriate, proportionate and represents the existing community’s needs.
A tool which uses similar technologies is VU.CITY, the first complete fully interactive 3D digital model of several international cities. Through VU.CITY, consultees can visualise proposed developments within the existing context of the area. VU.CITY can overlay the model with transport data, sightlines, wind modelling, pollution and sunlight paths. Dropping down to street level further helps consultees understand the proposed new developments in context. VU.CITY also incorporates information in relation to protected views and both existing and consented developments.
The logical extension of 3D modelling is augmented reality projection of proposed schemes onto actual landscapes. Along with a vision of how a new scheme could fit with existing infrastructure, augmented reality could enable the user to access additional information data-tagged onto the projected image.
Public participation which utilises modern technology is evolving rapidly and over the next decade we expect to see increasing use of large format touchtables and touchscreens which use geospatial data, weblinks and videos to provide additional information. Walk-through 3D models and virtual reality theatres will enable a shared experience of a digital representation in a planning workshop. Online ‘story maps’ which link text and images to a map have the potential to provide information about a proposal either though a desktop app or as part of a walking tour, supported by information on constraints and current land uses and proposals for development. Increasingly photorealistic, high-resolution representation of proposals will have the ability to depict alternative scenarios almost equivalent to reality.
Although it does much to benefit consultation, online consultation is not a panacea: this new selection of tactics presents a new set of risks. The fast dissemination of information online, although beneficial in many circumstances, can also be a disadvantage. In cyberspace, information can fragment quickly and become used by pressure groups to reinforce opposition. The extractive sector in the Arctic has been targeted by headline-grabbing activists and protestors from around the World who can rapidly spread news of their latest protests as well as misinformation regarding the extractive sector globally. The internet should be consistently monitored and procedures put in place to respond to concerns and misinformation.
Furthermore online consultation, particularly social media, can be seen as superficial and lacking in the emotional power and empathy that face-to-face communication can bring. Online profiles can mask identities and if measures are not put in place, it can become impossible to monitor the geographical origin of comments. Standardised response mechanisms which give online consultations a bad reputation should be avoided in most circumstances. And despite the increase in online communication, a digital divide still exists, particularly affecting rural, indigenous and older groups.
Certainly online consultation should not be used a means to reduce costs or labour. As with any tactics, the decision to use online consultation should relate directly to the consultation’s overall objectives, including the need to produce meaningful analysis.
As the capabilities of the internet, along with digital connectivity, grows, the opportunities for involvement within each of these categories will undoubtedly increase. Individuals’ power to use the internet as a means of protest will increase and therefore prospective developers must adapt and respond to this changing communications landscape.
In 1969 the US communications academic Sherry Arnstein identified the terminology of consultation in her Ladder of Participation. In some respects, Arnstein’s theory is a useful resource by which community involvement can be considered today.
Arnstein’s Ladder was intended to reflect the relationship between community and government, identifying poorly-led participation as ‘manipulation’ on the bottom rung of the ladder and rising to ‘citizen control’ at the very top.
My first reflection on this, along with many other consultation professionals, is that ‘consultation’ is rarely ‘tokenism’.
The dynamic process of dialogue between individuals or groups, based upon a genuine exchange of views, with the objective of influencing decisions policies or programmes of action.
It is dialogue, it is two way, and it seeks to gain feedback in order to inform decisions.
Furthermore, I think that most developers quite justifiably choose to ignore the top two rungs of the ladder – the best consultations are a partnership between a developer and the community, not a relinquishing of control to the community.
I also suggest alternating the positions of consultation and placation, thereby positioning consultation at the centre of the ladder, representing a process which involves local people and government / organisations equally. Ideally the fifth rung would be divided further to reflect the fact that consultation itself has many forms as shown below:
This, I hope provides a more up-to-date framework by which consultations can be considered.
Traditional forms of civic involvement have declined during the twenty-first century: trades union membership has almost halved since the late 1970s and now comprises less than a quarter of the workforce. Yet membership of special interest groups has increased substantially. Nearly 4.5 million people, or one in 10 UK adults, is now a member or supporter of one of Britain’s environment and conservation groups.
Single issue groups are those which exist to lobby on a specific subject. As such, they tend to be motivated by a notion of injustice or threat, or a need to bring about change. Successful single issue groups such as Make Poverty History, the Extinction Rebellion or Fathers for Justice were formed with a single imperative that unites members and as such they promote their messages very effectively, whether through protests, stunts or the media. There are many single issue groups which impact on planning, from international organisations such as Greenpeace, to local conservation groups. Because such groups have been founded on the basis of a specific cause, they can provide substantial opposition to a new scheme. The campaigning power of the internet means that despite a small budget, even a small membership, such groups can have a considerable impact. And because national groups quickly reorganise on a local level in relation to a specific proposal, they can have local relevance while drawing on their national strength.
Single issue groups do play an important role in the planning process. Where they have shown an interest in a proposal, every opportunity should be made to engage with them, to understand their point of view, to correct any misapprehensions which may exist and to take on board all feedback which is relevant to the planning application. The consequences of failing to engage with powerful interest groups will be significantly out-weighed by time taken to consult with them. And single issue groups are not necessarily a negative force in planning: developers frequently find that where a neighbourhood has several groups in place in response to an unpopular former planning application, those very groups may lend their support to a new proposal.
Special interest groups can also be extremely constructive in the case of a specialist facility. A developer of a specialist sports centre, for example, would benefit from consulting with those who already enjoy the specific sport. Not only will those with an interest provide valuable feedback to a consultation, but they may be extremely helpful in promoting and supporting it at a later stage in its development.
Increasingly, largely in response to the campaigning power of the internet, there has been an increase in the number of direct action groups which exist simply to campaign, rather than having formed around a specific issue.
Largely internet-based, groups such as these have a strong campaigning capability and considerable power to draw attention to an issue, locally, nationally and internationally. But most petitions simply state their support / opposition and as this is typically the extent of their involvement, it can be difficult to form any meaningful dialogue. Therefore the challenge is to identify, where possible, those behind the campaign and having done so, seek some meaningful engagement. Equally important is the need to mitigate any negative publicity, both online and offline, correcting misapprehensions and providing reassurance where necessary while also putting in place additional measures to promote more positive messages.
Protesting against the status quo, lobbying politicians, campaigning against organisations, cause-related fundraising and political campaigning have flourished in line with the accessibility of internet communications. Whether to inform, to mobilize or to bring about direct action, the abundance of communication tactics now available enables anyone to run a powerful online campaign. From local campaigns, such as a group of residents campaigning to save a beloved field from development, to international organisation raising awareness of a specific issue such as fracking, the internet can have a major impact on planning proposals.
As an innovative, informative, interactive, and a creative tool, online communications (specifically as a result of Web 2.0) have enabled increasingly sophisticated campaigning tactics which are almost certain to mature as technology advances. At little or no cost, a single individual is able to send a powerful message to likeminded audiences, the traditional media, and ultimately the public at large, with significant consequences.
It would vastly understate the power of the internet to describe ‘online campaigning’ as a single tactic. Most offline tactics can be replicated online and thus the presence of the internet immediately doubles the tools available to campaigners.
So what defines online campaigning as opposed to the offline campaigns of the last century?
Research and analysis: automatic alerts services, website analytics, social media monitoring are just some of the tools available to online campaigning which would take considerable time, effort and expense offline. Furthermore, the power of the web to quickly locate planning applications, local authority planning documents, government or pressure group documents and identify potential supporters considerably benefits campaigners.
Ease: the internet is becoming increasingly mobile, intuitive and accessible and thus significantly more user-friendly than offline alternatives. Taking part in a campaign in opposition to planning proposals online can be as simple as receiving a link via email and clicking on a hyperlink. Consequently those who may not have previously supported a campaign can do so with minimal effort.
Versatility: despite its worldwide presence, the web has an extraordinary ability to be tailored to individuals’ needs. While offline campaigns tend to focus on a selection of tactics, often based on practical considerations, the internet enables individuals to be targeted according to the communication tactic that most suits them personally, be it a text, image, report in PDF format, link to Instagram, Facebook, Twitter or YouTube. Again, this increases the likelihood of an individual supporting a campaign.
Dissemination: the capacity of messages to ‘go viral’ is phenomenal. A single email, Facebook post or YouTube video has the potential to be seen by millions within just minutes of having been posted. Messages posted within specific networks have the benefit not only of reaching millions, but of reaching the specific target audience very efficiently.
Information: unlike their print equivalent, documents can be posted on websites at little or no cost and in considerable numbers. Effectively there is no limit to the amount of information a campaign may include. Planning applications and local authority planning documents can be accessed at the touch of a button.
Speed: one of the greatest advantages of online communication, the speed by which a message can be communicated online is considerable. This results in campaigns gaining support extremely quickly.
Cost: at little or no cost, there is no limit to the number of online campaigns, resulting in campaigns existing where they may not have done previously.
New balance of power: largely as a result of low cost, the internet breaks down the perceived asymmetry between public bodies and the general public. Often individuals or small scale campaign groups are more agile and less risk averse than larger organisations and as such are more effective in executing an online campaign.
Mobilisation and co-ordination: the internet facilitates contact between individuals who share common interests and enables them to co-ordinate joint actions. It also has the potential to facilitate the formation of new political and social forces which may previously have been hindered by practicalities and resources. Powerful communities of interest can be formed regardless of geographical and social constraints.
Different dialogues: with internet communication offering dialogue in the form of one to one and one to many, the appropriate form of dialogue can be selected and used effectively. Furthermore petitions could be considered a form of ‘many to one’ and as such are a particularly powerful voice. Common to each of these forms of communication is two-way dialogue, which enables campaigns to grow quickly, also offering opportunities for more proactive developers to enter into dialogue with potential objectors.
Debate and discussion: it follows, therefore that debate and discussion can occur more easily on the internet than elsewhere. Online communication is an ecosystem founded on interconnected conversations and in many cases a campaign can benefit from positioning itself on an existing platform, such as that of a popular local website or blog.
Individuality: despite the potential to collate support, many internet-campaigns are initiated by an individual, because of the efficiencies afforded to them. A single point of view, if well timed and irrespective of the weight of popular opinion, has the potential to form a powerful campaign. Similarly, the internet enables campaigns to take place on a ‘hyperlocal’ level, as the next section demonstrates.
Low key: today’s activism need not be led by powerful personalities or instigated with great panache; in fact many online campaigns are anonymous. This brings about a lack of accountability which can distort a campaign and present difficulties for the organisations to whom the campaign is aimed.
It goes without saying that online, campaigns are potentially more sophisticated, informed, effective, efficient, adaptable, egalitarian and flexible than those that went before them. However, the use of the internet brings about new issues and concerns, one of which is the potential for misinformation. While the internet increases the opportunity for access to information, transparency and accountability, most websites lack the editorial filter that is an important part of professional news generation. It becomes the responsibility of users themselves to assess the veracity of information found online, but where this fails to happen, inaccurate information can be spread too easily.
Furthermore, campaigning has not shifted from offline to online: offline campaigns remain, and they remain successful (often because they are supported by online campaigns). This presents additional challenges to developers and therefore a need to understand how online campaigning works, understand the appropriate time to engage with a campaign, and do so effectively.
What is meant by ‘community’ and whether ‘community’ does it have any real meaning in the twenty-first century?
The Oxford English Dictionary[i] describes ‘community’ as: ‘a body of people living in one place, district or country’, and, ‘a body of people having religion, ethnic origin, profession etc in common’.
In planning, we tend to regard community in geographical terms, which is perhaps inevitable as a new development has a physical impact on a specific location. Furthermore, a local authority’s consultation will generally be aimed at the residents of that specific geographic jurisdiction. The OED’s second definition, however, should not be overlooked, as we will discuss later.
Doak and Parker (in their excellent, book Key Concepts in Planning – SAGE, 2012) offer a thought-provoking consideration of the term:
‘Community is a well-worn term that has been used and misused in public discourse and broadly across the political and social sciences. In planning terms much of the activity of planners is justified as being in the public interest but more and more the notion of community is attached to variety of planning processes, policies and actions. This common association of planning activity to and for community as both an end and a stakeholder group justifies an exploration of the term and its relevance for planners and in planning practice.
‘Community was seen as a political ideal in the ancient world, where citizens could participate in public affairs as part of the community. The concept has developed such that ‘community as belonging’ has come to be viewed both as a past state and as a desirable aspiration. Hobsbawm (writing in The Age of Extremes – Pantheon Books 1994) pointedly observes that, ‘Never was the term community used more indiscriminately and emptily than in the decade when communities in the sociological sense became hard to find in real life.’ Even more pessimistically, Bauman (in Community – Polity 2001) indicates that predilections towards recovering or developing community ignore the likelihood that it never existed in the first place.’
Doak and Parker’s sentiment eloquently voices the widely-held view that the term ‘community’ can all too often be used nostalgically, euphemistically and even patronisingly and that in some cases it is an artificial concept. To an extent, this is true in community involvement: there is also a tendency for those running consultations to use ‘community’ as a convenient catch-all for the streets neighbouring the proposed new development, or a mile, five or ten mile radius from the site. There are clear practical reasons for doing so, but it would be quite wrong to assume that a line drawn on a map by someone with little knowledge of the neighbourhood constitutes a community. Furthermore, it is equally inaccurate to assume that the supposed ‘community’ is a single body and likely to respond with a single view: as we know from our own neighbourhoods, rarely does everyone on one street, let alone wider neighbourhood, have an identical view on any one matter.
Changing geographic communities
Diversification is, in fact, one of the most significant changes in the concept of community.
The recent hey-day of the community was perhaps at a time between the end of the Second World War and the fragmentation which took place during the 1980s. Picture a scene from the 1950s or 60s: a street of terraced houses in a city previously damaged by war but still united by the blitz spirit, where the majority of occupants came from a similar social background, spoke regularly over the garden wall, read the local newspaper and attended the same local schools, social clubs and churches. They literally sang from the same hymn sheet: experiences were shared and there was an element of mutual trust, understanding and support.
Half a century later, it is extremely unlikely that the same residents, or indeed their families, still reside on that street. Increased multiculturalism will have led to greater diversity. Increased property prices and greater fluidity in the property market will have resulted in some houses having been extended, with others converted into flats, leading to a wider demographic. Attendance at the churches has probably declined, while initiatives to allow greater parental choice will mean that not all of the children attend the local school. Few residents will work within walking distance of their homes, with many commuting to the city centre or to a different town or city entirely. Furthermore, the community support officers who were employed to establish community relations post-war and the community arts projects which were popular during the 1960s and 70s are no more, as the case with many local newspapers.
The twentieth century community was by no means a utopia, but from a community involvement point of view, a geographically defined community was certainly a convenient starting point. There is significantly less homogeneity in local communities today. Global communication increasingly takes the place of local communication – whether in politics, business or leisure time. Increased car ownership, the availability of cheap flights and the ease with which travel plans can be made online has vastly increased the size of the communities within which people operate. Today it is easier to send an email to someone on a different continent than to visit a next door neighbour.
Changing communities of interest
It follows that the dissipation, and perhaps decline, of geographic communities results in the rise in communities of interest. This is perhaps best illustrated in the context of our leisure time. Previously, individuals’ experience of music would have been though participation, or attending live music in concert halls, pubs and social clubs. Today, much of the music that we listen to is online, or through electronic means. Live music is still popular today of course, but it is frequently consumed from across the Atlantic via the internet. Social media has enabled people to take part in live discussions in relation to a band or performance, and increasingly the internet provides opportunities for collaboration online. In sports too, participation and support of local clubs has declined partly due to the wide availability of sports coverage from across the world, while fan clubs, Facebook groups and to-the-minute discussions on Twitter are increasing levels of interaction irrespective of geographical boundaries.
It follows that in development, the community of interest is potentially global. Bicester Village, a designer outlet centre in Oxfordshire, attracts 14,000 Chinese visitors each year. Even for a single, specialist shop, the community of interest may be world-wide. The same is true of opposition to a development proposal: the community of interest, where a development involves building on open countryside, the demolition of a building of historical interest or the destruction of an important natural habitat, will be considerable and may come from across the country, or perhaps the world.
So communities certainly exist in the twenty-first century, but on a very different basis to those that went before them: communities are more likely to be linked by interest than by geography, than they were previously, and membership may be more passive, virtual and transient.
Of course, planning is usually with reference to a geographical feature and the immediate neighbours will remain a priority. But developers should also invest time in understanding the communities of interest that may put forward their point of view, whether in supporting a planning application or opposing it.
Online consultation is increasingly popular for many reasons, one of which is accessibility: parents of young children, the very old and the disabled, not to mention the time poor and commuters have all used online consultation as a means to engage on a development proposal.
But if online consultation is to be truly accessible – providing a service to those with visual and hearing impairments as well as others – it needs to be designed to incorporate some specific features.
Design well-defined, clear task flows with minimal, and intuitive navigation steps
Ensure that websites are accessible with directional controllers such as D-pads, trackballs or keyboard arrows
Allow functionality via the keyboard, rather than relying on the mouse, enabling those who use assistive technologies to access the website
Avoid controls that change function. If these are necessary, ensure that the content descriptions are changed appropriately
Make it easier for users to see and hear content by separating foreground from background
Ensure that web pages appear and operate in predictable ways
Ensure that buttons and selectable areas are of sufficient size for users to touch them easily
Provide time for content to be read and understood
Avoid having user interface controls that fade out or disappear after a certain amount of time
Bear in mind that HTML is quicker, easier and more widely accessible than PDF
Consider common forms of colour-blindness when determining colour palettes
Ensue that text size can be increased without detriment to layout or meaning
Ensure that the website is usable by commonly used screen readers such as JAWS, NVDA, VoiceOver for OS X, Window Eyes and Supernova and basic operating system screen magnifiers such as ZoomText and MAGic
Ensure that the website is compatible with speech recognition software such as Dragon Naturally Speaking
Provide content descriptions for user interface components that do not have visible text, particularly ImageButton, ImageView and CheckBox components
Use alt text for important images such as diagrams and timelines, enabling those who use a screen reader to understand the images
Where possible include standard interface controls in designs rather than custom built controls
Provide a text transcript of audio or visual files for people who are deaf or hard of hearing
Finally, evaluate success by asking for feedback and use this to make you next consultation even more accessible.
The rise of the ‘hyperlocal’ website is of critical importance to the planner, developer and local authority. Not only do hyperlocal websites play an extremely constructive role in promoting and debating local issues, they have considerable campaigning potential and such warrant an understanding by the profession.
The term ‘hyperlocal’, which originates from the US, describes online local services, which are usually run by local communities and residents’ groups.
Typical content is as follows:
News
Community news
Sports news
Events (meetings of local clubs or societies, community celebrations, key council meetings)
News of planning decisions or disputes, Local Plan and Neighbourhood Planning developments
News from local courts, police and schools
News submitted by local residents
Articles by local residents
Political
Election coverage
Borough and parish council news
Details of MPs, councillors and candidates
Engagement
Discussion forums
Information about local authority consultations
Networking
Information about local groups including residents’ associations
Information about local businesses
Campaigns
A range of local campaigns, often concerning local authority services, planning or construction work
Comment
Blogs
Images
Photo gallery
Information
Bus timetables
Local guides
Waste collection information
Hyperlocal websites tend to fill the gap left by local newspapers, and thus are both functional, informing people of local news and information, and also emotional, in giving people a sense of local belonging. They provide a new means whereby people can form an attachment not just to their city, town or village, but also to their neighbourhood and street.
Hyperlocals may be run by individual bloggers, small businesses or, in the case of Streetview and About My Area, national organisations. They each have in common the aim of improving the provision of local news, providing information and increasing opportunities for members of their communities to connect.
Williams, Barnett, Harte, and Townend have produced some very thorough research into the emergence of hyperlocal websites. In a comprehensive survey which explored, among other subjects, the reasons for forming a hyperlocal website, they identify that approximately 70% are instigated on the basis of active community participation; over half see their service as local journalism, and over half as an expression of active citizenship. In terms of online activity, nearly three quarters had covered local campaigns instigated by others, while over a third had instigated campaigns themselves. This frequently involved holding local authorities to account or forcing democracy in innovative ways. Campaigning tended to focus on failures by service-providers, the need for environmental improvements, cuts to local public services, improvements to local amenities, and local council accountability and planning disputes.
Campaigns around planning tend to focus on large scale developments, protecting green spaces, or protecting local businesses challenged by national chain stores. Campaigning for improvements to local infrastructure was also common, particularly in relation to local roads, train lines, cycle paths.
Aspects of Localism including Neighbourhood Planning, Community Right to Build and Community Asset Transfer frequently feature on hyperlocal websites, though Williams, Barnett, Harte, and Townend determine that, ‘The numerous campaigns mentioned against these…suggest concern in some communities about how democratic they actually are in practice.’
With so many online services (some of them blogs and Facebook pages rather than websites) coming under the rarely used category of hyperlocal, it is difficult to ascertain how many exist. A UK based website, Local Web List summarised, in September 2016, that there existed 546 in England,
The research by Williams, Barnett, Harte, and Townend reveals that there is a broad distribution of audience sizes amongst UK hyperlocal sites, with the great majority of sites having relatively small audiences. Just two of the websites surveyed claimed a monthly average of over 100,000 unique users, while 33 claimed between 10,000 and 100,000 and the remaining 55 below 10,000.
The future of hyperlocal sites is unclear. Some of the most proactive sites have already burned themselves out, overwhelmed by information and opportunities to campaign but struggling to do so with only volunteers to run the service. Those running and using the sites have high expectations for future development. This includes the use of GEO RSS feeds to provide local information via an app, increased use of video and audio, and pressure to carry out investigative reporting and use of Freedom of Information requests.The BBC, the Guardian newspaper and the Government’s Technology Strategy Board have made tentative steps to preserve local sites, but in many cases this has been met with objections on the basis that the raison être is that of community ownership.
On the other hand, as efficiencies increase, simple template websites become more readily available and as the retired generation becomes increasingly IT literate, their potential impact on development is likely to increase further. There is no doubt that producing around 2,500 news stories a week across the UK, hyperlocal websites have a role to play in planning and ongoing dialogue between a developer and a community.
In consulting on a specific proposal, the logical sequence of a strategy, however wide-ranging the involvement activities, establishes clear aims and objectives, enabling the development team to share values, expectations and understanding with local residents and organisations. A strategy is also the best means of identifying relevant issues, which provide context and insight as the programme progresses. The resulting communications programme is therefore a continuous cycle of research, engagement and evaluation, which can complement wider community development initiatives such as education, employment and healthcare.
A common mistake, often despite better intentions, is for a consultation strategy to become a retrospective document: the team launches into a series of tactics (perhaps based on past practice, experience or recommendation), results are collated, and then in a need to create a meaningful report, a ‘strategy’ is drafted to justify the approach. Worse still, and all too common, is to ‘predict and provide’, ‘plan, announce and defend’, or ‘plan, monitor, manage’. (These approaches are explained and critiqued elsewhere.) Each of these examples is a distinctly asymmetrical approach which makes scant use of local insight. Due to presumptions about a lack of a strategic approach companies should constantly aspire to disprove potential or actual allegations of ‘tokenism’, ‘box-ticking’ and ‘done deals’ through maintaining and communicating a highly transparent, symmetrical approach to consultation.
A strategic approach to consultation (detailed in the book and also in my earlier book Public Consultation and Community Involvement in Planning: a twenty-first century guide) requires a symmetrical flow of information between a potential developer and the local community and must prioritise continual engagement, allowing development proposals to evolve in line with feedback, and for the process to adapt where necessary. The strategic framework is not a ‘to do’ list, but a cycle: situational analysis, issues analysis and stakeholder database benefit from ongoing development; regular monitoring influences the ongoing selection of dialogue methods, and regular evaluation reinvigorates the strategic direction.
Consultation results are likely to disappoint local residents if the consultation has not been publicised adequately, opportunities for involvement are limited, consultation tactics are half-hearted and comments are not listened to.
Disappointment can fuel negativity – sometimes online, sometimes in the local media – and may well coincide with the point at which the planning application is being consulted upon by the local authority or considered by the planning committee. At this stage it is generally too late for developers to adapt proposals in the light of constructive comment, and faced with possible criticism at a planning committee, the options are to withdraw and amend the application or risk it being refused.
Appropriate research and planning provides a good basis for consultation and when this is done well local residents should not have grounds to object to the form of consultation. Importantly, (as described in my earlier blog) reference to the consultation mandate will enable the development team to negate criticisms of the process.
When effectively monitored, concerns about specific development proposals will be identified at an early stage, enabling responses to be addressed while the consultation is still live.
It is important to manage expectations. The potential for a substantial new facility impacting on their lives and a commitment on behalf of its sponsor to consult widely can raise expectations among local residents. If not met, high expectations can lead to criticism of the process and negativity towards the proposal.
Pre-consultation can enable a developer to discuss the remit and nature of the consultation with the local authority, special interest groups and in some cases, residents, at an early stage. Where a gulf exists between expectations and reality, this should become immediately apparent and can be addressed. Often the solution need not be to offer more by way of consultation, but to consult in a way which is more suitable to the specific community.
The process of consultation should be clarified in the consultation mandate and this document made widely available to ensure that those participating understand the remit of the consultation.
A keen interest – and particularly a positive one – can be welcome news but the development team should be conscious of over-promising and ultimately disappointing. Tactics should balance the need to motivate residents to secure their involvement, with tactics which will produce an appropriate level of feedback and a deliverable scheme. Sometimes the involvement of a ‘middle-man’, whether in the form of a local authority officer, consultation manager or community arts worker, can help manage expectations.
Evaluation of the consultation will be helpful in justifying the applicant’s actions and can make all the difference to the outcome: where a specific consultation framework has been put in place using pre-consultation dialogue and research, accepted by planners and run according to the consultation mandate, local authorities will understand that the consultation has met its objectives, despite local voices to the contrary.
Opposing factors and risks are common to public participation: the very notion that developers bring change to established local communities; the wide-ranging views which exist within a community; the sentiment of those wary of engagement and exponents of it. Significant time and financial resources are expended with no guarantee that the investment will be realised, and the focus on inviting comment on a potentially contentious issue can appear counter-productive to its eventual delivery.
However, an understanding of the potential challenges from the outset (and using issues analysis to further enlighten the process of understanding) can assist in mitigating risk.
In reality, potential problems fall into just a handful of categories, to which there are solutions. Two problems are common to the development team itself: resistance to public participation and a lack of dedicated resources. The first can be addressed by using workshops and training to gain buy-in from internal audiences, and the second by taking into account limitations at the outset, and planning accordingly. In the Arctic, travel poses particular challenges in terms of costs and staff time, and the use of technology is limited where a reliable internet connection is required.
Within the community, a common problem is a lack of understanding. This can be mitigated through provision of adequate information at the start of the process, in an appropriate voice and level of detail for the target audience; simplifying complex information and utilising professional communications skills as necessary. It goes without saying that those running a local consultation must be fluent in the native language. When inviting responses, it is beneficial to present information alongside questions to encourage understanding immediately prior to the questions being asked. Political interference is common whether in relation to national or local politics or in a powerful individual seeking influence others. Research and pre-consultation dialogue can develop an understanding of the community pressures and hierarchies and steps taken to mitigate undue influence. Initial research can be used to determine the most appropriate dialogue methods for each sub group. Lack of engagement is a common problem, especially when a community is suffering from ‘consultation fatigue’. To encourage engagement, a broad audience should be targeted, with the messages tailored to specific demographics and cultural sub-groups, particularly ‘hard to reach’ groups. New, creative and enticing methods can be used to increase engagement and time invested in both promoting the varied engagement tactics and the purpose (and potential impact) of public participation. Monitoring can be used to identify those successfully and as necessary, the strategy and tactics adapted to focus on the ‘missing’ demographic.
Developers are inevitably concerned when a consultation returns a negative set of results, though this generally inevitable given that a community faced with change is likely to respond only if it resists change – it is notoriously difficult to gain feedback from those who tacitly accept change. This will be taken into account and balanced with other factors when a decision is taken. Research can be used to identify potential negativity and address issues at the first opportunity. Development teams should bear in mind that criticism is frequently constructive, and so negative responses should be interrogated to gain useful information and identify the true cause of concern. Further dialogue and the use of facts can counter misinformation. Negative responses which are a result of pressure groups or activists can be identified as such and, where appropriate, such feedback viewed as separate to the results of the target community. To counter the impact of such groups, it may be possible to use local ‘ambassadors’ to provide a bridge between the developer and the community. Developers are also advised to work closely with the media from the early stages of the project with the aim of securing balanced coverage.
It is immediately apparent when considering challenges to public participation a majority of all problems likely to arise are in the domain of the development team: issues relating to access, clarity, communication, creativity, failure to respond, inadequate promotion of information, resistance to engagement, a lack of resources and time are common issues with communications plans generally and can each be addressed prior to the consultation commencing.
Advice on how to address the external issues is provided in greater depth in my earlier book, Public Consultation and Community Involvement in Planning: a twenty-first century guide. In considering the challenges, it was immediately clear that most problems can be resolved by following the strategic process: situational and issues analysis and pre-consultation dialogue enables the development team to identify many of the potential problems that may occur, understand and manage expectations, and determine the most appropriate tactics to use; stakeholder analysis will identify the range of local audiences to be involved, from political and community leaders to those regarded as ‘hard to reach’, an develop and understanding of how best to involve them; the aims and objectives, as communicated through the consultation mandate, help address any criticisms of the consultation in terms of its breath, reach and use of the results; consistent messaging in the form of a Frequently Asked Questions document will ensure that the whole development team is able to address difficult questions, and agreement with the local authority over the strategic overview will provide the basis for a good relationship between the development team and local planning authority. Resource allocation will prevent issues such as capacity to respond, and monitoring will help identify and respond to any problems as they occur. Finally, monitoring, analysis and evaluation all play an important role in explaining the reasons for consultation results.
Looking ahead, is consultation likely to see such significant change in the next twenty years as it has done in since the Millennium? I address this in my third book, Communicating Construction: insight, experience and best practice which is due to be published in March 2021.
With the speed of change we are seeing at the moment, specifically the publication of the Government’s Planning White Paper Planning for the Future, there is a danger that this will soon be out of date!
Political will is likely to dictate future change. At the time of writing, a Conservative government is responding to both the lack of housing and change on the high street by increasingly introducing permitted development rights. The absence of planning consent in such cases removes the need for local consultation and consultation requirements are reduced. Simultaneously, the former Labour planning minister Nick Raynsford, was appointed by the TCPA to review the planning system and the recommendations within his report, Planning 2020, are for significantly more consultation and community involvement in planning. The future requirement to consult appears to depend on what is currently a very precarious political balance.
Politics aside, and regardless of a legal requirement to consult, consultations are increasingly scrutinised though the courts, necessitating a good awareness of consultation law among all communications teams.
As a result of these trends, and thanks to some excellent training and guidance provided by the Consultation Institute, consultation is becoming increasingly professional. Quality assurance, consultation industry standards of practice, professional accreditations and CPD have contributed to this. In future I would hope to see the creation of a ‘good’ consultation kitemark for the industry, increased training for planning consultants on consultation, and a formalised means of best practice across industry, specifically on subjects such as online consultation, evaluation and analysis, and the use of co-production. This, together with adherence to the strategic process, will help address the challenges that we currently face.
Understanding of the potential challenges from the outset is necessary in order for them to be addressed – so what are the reasons for common problems?
Access
Failure to engage with a wider audience, specifically the ‘hard to reach,’ and to gain responses from the ‘silent majority’.
Apathy and consultation fatigue.
Clarity
A lack of clarity about the aims of participation leading to disaffection.
Communication
Failure to explain the situation and its limitations effectively.
Creativity
A lack of creativity resulting in a lack of motivation.
Disappointing results
Negatives responses, perhaps as a result of a campaigning by pressure groups, and negative media involvement.
Failure to respond
A failure to respond to or act on the outcomes of participation.
Inadequate promotion
Lack of awareness of opportunities to participate.
Information
Provision of too much or too little information, or failure to simplify complex information.
Managing expectations
Disappointment in the consultation by those being consulted.
Political interference
Unwelcome involvement of those with a political agenda beyond the scope of the consultation.
Resistance within the development team
An internal culture which is inclined to limit consultation, lacks trust in the process, provides too little information, too late, and fails to listen to feedback.
Resources
Lack of dedicated resources (people, funding, technology).
Time
Unreasonable timing, causing a consultation to be rushed, ill thought-through or otherwise compromised.
What is immediately apparent from this list is that at least half of the problems likely to arise are in the domain of the communications team: issues relating to access, clarity, communication, creativity, failure to respond, inadequate promotion, information, resistance, resources and time are common issues with communications generally and can each be addressed prior to the consultation commencing.
Advice on how to combat the external issues is provided in greater depth in my book Public Consultation and Community Involvement in Planning: a twenty-first century guide. In writing about addressing the challenges, it became immediately clear to me that almost all problems can be resolved by following the strategic process: situational and issues analysis and pre-consultation dialogue enables the communications team to identify many of the potential problems that may occur, understand and manage expectations, and determine the most appropriate tactics to use; stakeholder analysis will identify the range of local audiences to be involved, from political and community leaders to those regarded as ‘hard to reach’, and develop and understanding of how best to involve them; the aims and objectives, as communicated through the consultation mandate, will help address any criticisms of the consultation in terms of its breath, audiences and use of the results; consistent messaging in the form of a Frequently Asked Questions document will ensure that the whole development team is able to address difficult questions in a public setting and agreement with the local authority over the strategic overview will provide the basis for a good relationship between the development team and local planning authority. Resource allocation will prevent issues such as capacity to respond and monitoring will help identify any problems as they occur sot that they can be acted upon quickly. Finally, monitoring, analysis and evaluation all play an important role in explaining the reasons for consultation results.
With pre-planning consultation complete and planning consent won, a significant amount of public participation has been accomplished. But as the project moves into the construction phase, community engagement too enters a new phase.
Inclusive and engaging consultation creates a foundation for the next stage of public participation. But rather than a continuation of the work to date, community engagement post-planning has new aims and objectives, new stakeholders and new challenges. The development team will change. A proactive approach towards community relations is required to ensure a constructive relationship between all parties.
The process of construction is rarely popular and where negative sentiment already exists within a local community, a developer has an uphill struggle to deliver a project while maintaining a good reputation. And once work begins, that relationship can be further strained due to frequent movements by construction vehicles, the noise of pile driving, road closures, parking cessations, occasional cuts to power supplies and numerous other, often unpredictable, consequences of construction.
A good relationship with the local community enables the development team to minimise disruption and pre-empt future problems: regular dialogue with residents can identify problems before they occur.
As with consultation, a community relations strategy should begin with local dialogue. Meetings with those most affected and stakeholder groups representing the wider area will enable the developer to understand both fears and expectations and put in place channels of communication for the future. While previous research is a useful starting point, the developer must be cognisant that interested parties may change at this stage, especially with the addition of new users and occupiers.
Good community relations is both proactive and reactive and is not limited to mitigating the impact of construction. The community relations strategy for a medium or large scheme might also include outreach activities, perhaps involving education, the environment, art and employment initiatives. This proactive approach is a positive means of reaching a local audience and involving them in the project through relevant and appealing tactics.
The appointment of a community liaison officer is an excellent starting point as this ensures a single point of contact for local residents and a co-ordinated and consistent approach. In some cases, this may be served by a Construction Impacts Group or development forum. Newsletters, emails, a community relations website and social media, telephone helplines and exhibitions in local community centres have been found to be useful in imparting information. Face-to-face and small community group meetings enable the development team to speak directly with those affected and respond to concerns. Community liaison panels are a more formal means by which the construction project can understand residents’ concerns, but are smaller and more manageable than public meetings. A simple means of sharing news about the development is to provide plastic windows in hoardings, enabling local residents to view progress on site. This can also be provided through the use of a webcam or time-lapse photography, hosted on a website or social media page. Other ideas used to encourage local residents to engage with the development team include the creation of community reporters (local people given the opportunity to interview the development team and report back to the community in the form of a newspaper or blog) and a regular drop-in café to encourage direct communication between the construction team and community. Contact with the local media can be a useful means of providing updates to the wider community and also establish a positive relationship with the local media which can be useful in the case of complaints. The development team also has the opportunity to involve the community in events, such as ‘topping out’ a significant building or opening a community facility.
When the last construction vehicle has left the site, what is the developer’s responsibility to the new development? The Impact Benefit Agreement negotiated between the developers, local and central government and possibly other local organisations will set legally binding requirements or targets for local employment and training as well as contributions to local projects. While this provides an opportunity for the developer to work constructively with the local community, that good intention can misfire if problems arise elsewhere, or if the needs of certain sections of the community area not met, hence the ongoing need for research and dialogue.
Ideally the early stage of strategy formation in a consultation programme should assess the context of the consultation as broadly as possible to ensure that all factors are taken into account. Useful methods for situational analysis are the PEST (political, economic, social, and technological) and SWOT (strengths, weaknesses, opportunities, threats) methods.
Stakeholder analysis is central to any consultation and the spectrum of stakeholders for a single extractive project – let alone ongoing engagement with a wider community – is considerable. Stakeholders include not only those likely to be impacted by the proposed change, but those instrumental in communicating with the communities affected. Without understanding the quantity, diversity and informal spheres of power and influence that exist in the community, engagement runs the risk of failing to reach sections of the community and is thus asymmetrical. Stakeholder mapping enables the development team to understand a specific individuals’ likely views (be they positive or negative) and to assess the relative interest and potential impact of key individuals and groups. A thorough understanding of the community also informs later stages of strategy development, for example, ensuring that tactics are well suited to specific groups.
Having identified a broad range of factors impacting upon the consultation and those most affected, development teams should consider the specific issues likely to dominate the conversation. In communications theory, an issue is regarded as an unsettled subject ready for debate or discussion. Knowledge of issues enables the potential developer to better understand the broad context of local sentiment, in addition to existing and potential concerns. At the start of the engagement process, it benefits all parties for the developer to create a Frequently Asked Questions document which sets out each of the issues likely to arise alongside an agreed response. An embodiment of the transparency that any potential developer should aspire to, the document must above all be honest and open. It should also be flexible, as issues will change during the course of the project and themes will emerge or develop as new topics are introduced.
It goes without saying that electronic communication has enabled a more scientific approach to research. I recently set up an online consultation platform in which all data collected, from comments in meetings to online polls, was collated, enabling me to present the client with an up to date consultation report as often as required, at the touch of a button. It is hard to recall how twenty years previously the developer would have had little knowledge of resident sentiment until the end of the consultation: today, issues management is a key strategic element of any consultation and we have created the tools to easily identify emerging themes, possible misapprehensions and potential ‘ambassadors’.
With the transition to participatory planning, consultation data has moved from being predominately quantitative to predominately qualitative. Qualitative data – observations and comments, usually expressed in words rather than in numbers both provides a context for quantitative data, and enables the consulting body to get to the heart of an issue. And again, recent technological developments – specifically in coding and mention analysis – have brought about a more effective means of measurement.
Due to the absence of a requirement to consultation in some planning scenarios, consultation in planning is not governed by strict rules and regulations as the consultations carried out by public bodies. However, the legal aspect is important because simply using the term ‘consultation’ creates expectations which can be challenged in the courts.
There are several ‘layers’ of law which affect public consultation.
Environmental – the requirement to carry out Environmental Impact Assessments which is based on the ‘Three Pillars’ of the The Aaarhus Convention (Access to information, Public participation in decision making, Access to justice)
The Doctrine of Legitimate Expectation – where courts recognise consultees’ right to expect a thorough consultation
Common law – which rests on an increasingly substantial amount of case law.
Gunning 1: when proposals are still at a formative stage
Consultations have been found to be at fault on this basis if a decision has already been made; if the critical question is avoided; if consultees are not consulted on all options; if a single ‘over-engineered’ option is the only option; if the options are portrayed inaccurately.
Gunning 2: sufficient information to give ‘intelligent consideration’
Case law includes promises for an extensive consultation being broken; a lack of transparency in options development; failure of the consulting body to give adequate reasons for decisions made; unclear information; failure to ask the right questions; failure to provide adequate information; proposals not adequately communicated.
Gunning 3: adequate time for consideration and response
Failure at this hurdle has been the result of the consultation process not being visible or effectively publicised, inadequate time being allowed for responses, and inappropriate phasing.
Gunning 4: must be conscientiously taken into account
Consultations have been taken to court because of inappropriate weighting of consultation responses, the withdrawal of options before they have been consciously considered, failure to summarise responses adequately, unfair reporting of consultation outcome, failure to consult ‘out of area’ consultees and failure to re-consult if situations / options change.
The ‘three pillars’ (Articles 4-9) of the Aarhus Convention
The Aaarhus Convention stipulates three public rights which have become an important benchmark in consultation, specifically in relation to dialogue between the public and public authorities:
Access to information
Public participation in decision-making
Access to justice
The Doctrine of Legitimate Expectation
The Doctrine of Legitimate Expectation originated in United Kingdom and has since become incorporated in the other common law jurisdictions in relation to the practice of public bodies.
A procedural legitimate expectation exists when an organisation commits to following a certain procedure – such as consulting – prior to making a decision. If the expectation to consult is created but not delivered upon, the organisation may lose a Judicial Review on the basis of failing to comply with the Doctrine of Legitimate Expectation.
In recent blogs, I’ve focussed on my work with the Environmental Working Group of The Consultation Institute and the need for a clear strategy.
In the time that we’ve been planning our work, Covid-19 has changed everything, and it’s certainly had a significant impact on discussions about climate change. The points below show just a few ways in which climate change engagement strategies have been impacted.
A better understanding of adaptation and mitigation: in very little time we learnt to adapt (work from home) and mitigate (wear a face mask), and we did so generally successfully
An ability to accommodate new priorities: where society acknowledges the acute need to act, drastic measures can be implemented in a short period of time.
Changed attitudes: because of the severity of the situation and because people have had time to reflect, there is a renewed appreciation of aspects of life such as community and open spaces.
Fresh views of decision-makers: Covid-19 has changed our view of governments and their role in society, mostly in a constructive way. Research carried out in March showed massively improved approval ratings for Boris Johnson, Angela Merkel, Emmanuel Macron, Justin Trudeau, Scott Morrison and even Donald Trump. With heightened popularity, these leaders have a real opportunity to inspire and motivate on climate change mitigation. And it’s not just world leaders – the same is true at a local level, with more trust for local authorities.
New opinion-formers: doctors and medical professionals are the new heros. Globally, they are calling on world leaders to ensure a green recovery from the coronavirus crisis and they will be listened to.
The benefit of clear messaging: Covid-19 shows that with clear, tangible communications and direction, people will respond. And this is not unseen in an environmental context – recycling, and a reduction in use of plastic bags, coffee cups and straws is an example of this.
Changing flows of information: media coverage issues such as climate change will always fluctuate in relation to the news agenda – as this data shows very clearly; but that does not mean that it is of any less concern in individuals’ minds.
New ways of working together: from the Oak National Academy providing educational resources across the country, to communities showing their appreciation for carers on a Thursday night, we have worked together in many different ways.
Changed forms of communication: while community meetings are not possible at the moment, as we’re all demonstrating now, people quickly find ways to adapt.
‘Collective efficacy’ can be effective: the public response to Covid-19 has shown that people can act together in response to an external threat. This could be used to demonstrate that individual change is a crucial part of wider systemic change.
A warning about the vulnerability of society: according to an article in The Lancet, The Covid-19 pandemic should be a wake-up call that our global economy is far less robust to shocks than we have become accustomed to believing.
The ultimate outcome: we now know that we can have cleaner water, less air pollution and that people can be encouraged to use more sustainable forms of transport.
Finally, a new IPSOS poll conducted in 14 countries found that 71% of adults globally agree that, in the long term, climate change is as serious a crisis as Covid-19 is. What better mandate could we have for pressing ahead with climate change engagement strategies?
For anyone planning to engage on climate change – especially those who put in place a strategy prior to the coronavirus crisis – it’s also very important to understand how these factors have changed the environment for discussions, not only now but in the years to come.
If you’d like to find out more about the Environmental Working Group, view the web pages here or contact me directly.
Following on from my earlier blog about the need for a comprehensive engagement strategy on climate change issues, I plan to look at some of specific elements of the strategic framework in a bit more detail, starting with messaging.
Climate change is such a broad subject, it’s not surprising that it has many conflicting messages attached to it. This invariably creates complexities for those of us running climate change engagement programmes.
Consider the following:
Sentiment versus fact: In communications on environmental issues, there is no absence of either, but whereas some people are motivated by sentiment, other are more motivated by fact. A good communications strategy needs a combination of the two.
Personal experiences and the bigger picture: The message must have personal relevance – but not at the expense of the main issue. People should be encouraged to input on the design of new cycle routes – but they should also be aware of the depleted polar ice caps.
Experiences vary: recent research by IPOS MORIdemonstrated that in Colombia, South Africa, Chile, Peru, India and Malaysia, over 80% of the population said that if their government does not act now on climate change, it will be failing them. Meanwhile in Germany, the US, Sweden and the Netherlands, the figure was less than 60%: presumably a reflection of relative experiences of global warming.
Changing behaviour through both ‘carrot’ and ‘stick’: There’s certainly both ‘carrot’ and ‘stick’ in climate change communications: encouraging walking, cycling and public transport, while discouraging unnecessary journeys and unclean fuels for example. A positive campaign should encourage good behaviour but avoid shaming hypocrisy.
The need for both individual and collective responsibility: We need to focus on both individual experiences and the bigger picture. Our unusually sunny summer was part of the same warming trend that ignited California and Australia’s wildfires, but to many the connection wasn’t clear.
Mitigation and adaptation as solutions: Mitigation and adaptation may require some explaining. It’s also important to communicate the fact that they aren’t mutually exclusive – neither one will solve the problem. Both are required to tackle the issue successfully.
So what can communications professionals do to make sense of these conflicting messages?
Importantly, we must acknowledge that they exist. Some dichotomy is inevitable in such a complex scenario.
Where possible, we should opt for a suitable balance – for example, of adaptation and mitigation solutions – as audiences will respond differently. Adaptation requires pragmatism, rationale and a broad understanding; mitigation is invariably more emotionally-driven. But both are relevant.
Delivery of the messages must be finely tuned. Messages must be real; they must balanceemotional understanding and scientific fact, avoid technical jargon, and where appropriate, use data to back up facts. It is important to avoid being too sensationalist. To claim that each successive summer is getting hotter, for example, is inaccurate and threatens to destroy the credibility of the overall message.
Consider using trusted voices. Since the Covid-19 crisis, doctors (today’s new super heros) and scientists (officially the most trusted profession) are increasingly seen as opinion formers. In fact they’ve recently called on world leaders to ensure a green recovery from the Covid-19 crisis. And they will be listened to.
And finally, while top-line messages must remain consistent, language, tone and means of communicating them will change depending upon the audience.
In my experience, the answer to most communications questions comes back to strategy: if you get your research, issues analysis and stakeholder mapping right and adapt the strategy as the situation changes, you have a secure basis upon which to form an engagement programme.
If you’d like to find out more about the Environmental Working Group, view the web pages here or contact me directly.
In the Consultation Institute’s Environment Working Group’s first webinar we outlined our belief that the recovery from the Covid-19 pandemic has huge potential as a ‘green’ recovery.
In the last three months the nation has been shocked by the pace at which disaster can occur and consequently concerns about climate change have been brought to the fore. But we’ve also been encouraged by positive impacts including cleaner rivers, reduced air pollution, the ability to enjoy birdsong and more recently the introduction of a ‘café culture’ in Britain’s town centres – much of which is detailed in IPSOS MORI’s excellent report Now What? Climate change and coronavirus.
This progress can only continue if the Government’s ‘Infrastructure Revolution’ comprehensively addresses the need for greater sustainability.
Its early days, but already polling shows that people expect to adapt to a more sustainable lifestyle. Research carried out by Centre for London in June revealed that 69% of Londoners support the widening of pavements and 64% support the provision of new cycle lanes. The experience of the lockdown has also increased understanding of the need for additional parks and outdoor spaces (especially in areas of high density), fewer high-rise balcony-less apartment blocks and increased circulation space on our high streets. Additional opportunities for a sustainable recovery include the creation of an infrastructure for electric cars, provision of higher environmental standards in new housing, and investment in renewable energy and a commitment to biodiversity.
Without question, the substantial funding for infrastructure which was announced earlier this week is fundamental to our financial recovery – but to ‘build, build, build’ without taking the time to fully address critical environmental issues, future-proof construction would negate the substantial progress that has been made towards a ‘greener’ future. There is a danger that a rush to convert shopping centre into homes, for example, creates car-dependent unsustainable communities which deny their inhabitants the most basic rights of natural light and fresh air. It is imperative that progress focusses on the creation of new infrastructure which incorporates effective sustainable initiatives.
This requires careful consideration – and engagement. Reforms to the planning system must not fast-track construction at the expense of dialogue as is all too often the case when Permitted Development Rights are extended. Engagement is never more important than at times of change. And in policy-altering, nation-wide initiatives which impact on the nation’s economic, physical, emotional and mental health, everyone is a stakeholder.
So how should the Government and the innumerable parties involved in instigating change go about doing so?
There is clearly a need for a ‘big conversation’ on a national level, to understand people’s shifting priorities and expectations. And because change affects communities directly, dialogue at a local level is equally, if not more, important.
Ironically, the potential to engage on the opportunities created by the pandemic are also limited by it.
Many means of engagement have changed irrecoverably: it will be some time before consultation involves a packed town hall, touch-screens in busy shopping centres or children using Lego to depict their aspirations.
However, in the absence of traditional means of consultation, we’ve seen a rapid proliferation of alternatives, including community meetings hosted on Zoom, virtual exhibitions and workshops, interactive maps and online focus groups. Not all emerging methodologies are restricted to the internet: there has been an increase in community call-ins on local radio shows, consultation by telephone and the use of community groups’ own channels of communication.
In better utilising existing community groups, the organisation co-ordinating the engagement process may need to invest greater time in the stakeholder mapping process, but this will pay dividends long term.
Online consultation has multiple benefits including the ability to communicate immediately and target precisely; increased accessibility – including for those with hearing and sight impairments; the ability to structure real-time dialogue and an exchange of ideas on a one-to-one, one-to-many and many-to-many basis; multiple means of promotion, and an efficient means of data collection and analysis.
The effect of lockdown has vastly increased the consultation toolbox and therefore the quality of engagement, though only if we select the tools carefully.
So it is important that in engaging on an issue of this size, scope and importance, a strategic approach used. This benefits information-gathering, scoping, monitoring and analysis in addition to – as mentioned above – stakeholder mapping and campaign planning.
The Prime Minister’s 30 June speech concluded, ‘We will not just bounce back, we will bounce forward – stronger and better and more united than ever before.’ There is clear evidence of the inclination to bounce forward, stronger. But as for ‘better’ and ‘more united’ – this depends on the quality of the engagement and whether it focuses on what really matters.This article was written for The Consultation Institute Environment Working Group and published on 2 July 2020.
There is no denying the fact that the impact of climate change is substantial, universal, and requires both adaptation and mitigation.
Even amid the current Covid-19 crisis, climate change remains a pressing issue – if anything the issue is highlighted by the evidence that clean air, clean waterways and more sustainable living and working practices are achievable. Unsurprisingly there is much discussion about the need for a ‘green recovery’ to the Covid-19 crisis.
With other Associates of The Consultation Institute (tCI), I have formed an Environmental Working Group which will be instrumental in helping put in place ‘big’ conversations on climate change adaptation and mitigation, with a strong emphasis on economic and social recovery.
The need for engagement
Efforts to address climate risks will not succeed without a ‘social mandate’ – the buy-in of those whose everyday lives will change as a result. And that’s all of us.
That’s why we consider engagement with individuals and communities as imperative.
Concerns about the climate are rising up the agenda. Research carried out among the British public earlier this year by Climate Outreach found that climate change was second only to Brexit as an issue of national importance. It also found that levels of worry about climate change have doubled in the last four years and that scepticism about climate change is very low, with more than 85% of agreeing that climate change is driven by human activity.
The challenge is to move people on from concern to commitment.
Engagement, not consultation
We see wide-scale engagement, carried out both at a local and central government level, as being key to this.
Why engagement and not consultation?
Conversations on climate change aren’t a single, one-off with a specific question to be answered: although they may comprise several individual consultations, they are primarily ongoing
The dialogue takes place over many years – decades even, with no prescribed end date
The context is broad and will change during the course of that time – Covid-19 has massively impacted the debate, as will many future factors
And because of this, our background intelligence, stakeholder mapping and the ways in which we engage will continue to change – requiring a flexible engagement strategy rather than a fixed consultation
tCI’s Environmental Working Group
So engagement on climate change is not straightforward: far from it. While being highly susceptible to external influences, it requires a strategic approach: one based on research and clear objectives, one which is flexible in the face of change but consistent in its purpose, and delivers sound feedback data.
It is because of this that we established the Environmental Working Group. Our purpose is to advise local authorities and other organisations on their engagement activity through an understanding of the regulations (such as the Aarhus Convention and the Paris Agreement), to review governance issues (typically responsibility for climate change engagement will be spread widely across an organisation), to hold workshops (on topics such as scoping, stakeholder mapping and behavioural change) and to assist with running communications campaigns as required. We are also able to advice on governance, and provide e-learning and training through workshops.
If you’d like to find out more about the Environmental Working Group, view the web pages here or contact me directly.
The book demonstrates how effective public participation is fundamental to the process of change brought about by extractive industries.
Not only should residents be involved whether as a legal requirement or simply through courtesy, but feedback from the community – from anecdotes and folklore to information about current uses of a proposed site – significantly benefits a proposal. In this context, ‘public participation’ is viewed as the long term process of engagement, not necessary linked to a specific extraction project but concerning community relations between an extractives company (or companies) and a community over many years; in contrast to ‘consultation’, which typically refers to the process of gaining feedback on a specific proposal and as such forms part of a broader public participation programme. Both involve extensive research, multiple stakeholders, an appropriate (and therefore diverse) selection of dialogue methods and comprehensive evaluation. A strategic approach provides the framework to do this in a cohesive manner.
While each unique project requires a unique approach to public participation, a standardised approach to strategy can ensure that all relevant factors are taken into account and produce an appropriate public participation programme.
My chapter will exemplifies best practice strategy and tactics for consultation, and new methods of engagement as used in the UK, Australia and Canada.
Communications theorist Grunig identified four models to demonstrate ‘excellence’ in communication: press agentry, public information, two-way asymmetrical and two-way symmetrical. His epitome of excellent communication is the two-way symmetric model – an entirely symmetrical relationship:
that is based on research and that uses communication to manage conflict and improve understanding with strategic publics.
Individual countries’ legal requirements to consult on a planning proposal vary considerably. For example, the granting of an exploration licence for onshore mining activities in Greenland does not require a social impact assessment; which contrasts sharply with the UK, where community engagement in relation to similar schemes must follow a stringent process – the NSIP process, which is detailed in the 2008 Planning Act.
Regardless of whether there exists a legal obligation to consult, there is not a legal obligation to uphold the majority views revealed in the consultation. Consultation is not a referendum. According to the UK’s Consultation Institute, consultation is:
The dynamic process of dialogue between individuals or groups, based upon a genuine exchange of views, with the objective of influencing decisions policies or programmes of action.
Recommendations for change following consultation take into account both technical and financial factors alongside stakeholder views – which, technically, may or may not be upheld by the decision-makers.
So, neither consultation nor public participation results in a definitive decision, but the notion that public participation can benefit planning decisions is unequivocal. Effective public participation can create lasting positive relationships between a developer and a community, can produce local insight which significantly benefits any resulting development (specifically in tailoring it to the local community), and through dialogue, identifies appropriate community benefits.
In the epicentre of a crisis, looking to the future can seem both pointless and worrying. But longer term, challenges can create positives – consider the career opportunities for women following WW1 and the establishment of the NHS following WW2.
The potential impact of coronavirus on the development sector is significant, not just today but long, long term. But the housing shortage won’t go away, new infrastructure is desperately needed and despite a temporary ban on face-to-face contact, there are huge benefits in involving people in future plans.
An immediate impact of the coronavirus crisis is that many community consultations on planning decisions will be cancelled – and quite rightly so.
But simultaneously the crisis is changing the way in which we are using the internet to communicate – whether for family gatherings hosted by Skype, music lessons on Zoom or training webinars. Changes in the ways in which we communicate will not be limited to the current lock-down: those that are shown to work will be here to stay.
In planning, the absence of community meetings can be met by online consultation, which is inexpensive and easy to put in place. And with so many social activities cancelled and people in lock-down, the audience is ready and waiting.
There are many reasons why developers increasingly choose to use online consultation:
Research: The internet is by far the most powerful research resource. A substantial proportion of information that is required in researching stakeholder groups and necessary background information is freely and readily available.
Issues management: A constructive consultation is based on the community having access to reliable information, which can be easily sourced online. Monitoring of online consultation provide an immediate and effective means of understanding local sentiment and identifying any misapprehensions.
Immediacy: Online consultation has the advantage of being immediate: information can be posted and responded to in minutes. But consultation timelines should not be shortened as a result. On the contrary, immediate communication can only take place if the audience has been targeted and is in receipt of the message. Online communication can potentially spread quickly but only if the message is strong and compelling.
Ease of access: Online communication is a medium in which many people choose to communicate and by targeting residents via their preferred means, the likelihood of involvement is increased. Users can take part in an online consultation when and where they want – at home, on the move. Many chose to do so late at night. Because of its increased accessibility, online consultation has the power to reach new audiences – particularly the young and the time-poor. Local authorities welcome developers’ inclination to consult more widely; simultaneously this enables developers to unearth the support of the ‘silent majority’.
Dialogue: Online consultation allows for real-time dialogue and an exchange of ideas on a one-to-one, one-to-many and many-to-many basis.
Removing hierarchies: Online consultation has no regard for the limiting social stratas that we impose on ourselves. In a busy public meeting, for example, attendees may defer to a dominating character or group leader. Ultimately those members are not adequately represented, despite their presence. Online, and particularly behind the veil of a username, individuals are more likely to voice opinions without fear of repercussions, while personal details remain confidential but are accessible to the local authority as a confidential appendix to the consultation report.
Reaching ‘hard to reach’ groups: Many people – particularly commuters, families with young children, the elderly and disabled – are not easily able to attend consultation events. Online consultation provides an alternative, accessible means of engagement. Online consultation can be accessible in both its language and in the varied ways in which information is presented.
Promotion: Social media, blogs and the local media online can assist in communicating messages quickly.
Moderation: Both websites and social media can be monitored effectively. The way in which a consultation is to be moderated should be determined at the start and ideally communicated via a user guide to ensure consistency. For example, it should be decided in advance whether user generated content is to be vetted before appearing and if so, on what basis comment might be withdrawn.
Analysis: Online communication can be very effectively analysed: comprising day-by-day website usage; average session times and bounce rates; analysis of the most popular pages; demographic information in relation to location, gender, age and interest; analysis of how people are reaching the website; results per poll / forum / survey / blog comment; maps to depict the location of respondents. Likewise qualitative analysis which combines a technical and human approach can be more sophisticated than offline analysis.
Feedback: A consultation website, email and social media provide ideal means for communicating feedback.
Using online consultation can help us to keep the industry moving, continue to address the housing crisis and avoid job losses.
Another long-term prediction I have for the post-coronavirus renaissance is a strengthening of communities. Absence makes the heart grow fonder, and I predict that when the crisis is over we will be only too pleased to replace an evening in front of a DVD with a round in the local pub. Likewise those who have offered or received community support will have renewed faith in their communities. From a planning perspective, I anticipate higher levels of involvement in decisions that impact on our neighbourhood, especially where community facilities are proposed. I will welcome the resumption of community meetings and public exhibitions, but I also see a continuing role for online consultation in complementing face-to-face communication.
Researching likely consultees at the start of the consultation process ensures that the consultation strategy takes into account the appropriate number of residents to be targeted, the diversity within the community and an understanding of where power lies. Without it, the consultation runs the risk of being asymmetrical and failing to reach certain sections of the community, which often includes the ‘silent majority’ – those quietly accepting of the proposals.
A thorough understanding of the community also informs later stages of the strategy development, for example, ensuring that tactics are well suited to specific groups. It enables the consultor to better understand the issues that motivate groups and individuals – something which may not be immediately apparent or may contradict initial perceptions. In a recent case, a political party supported a policy to bring about housing on a specific site, but despite being a member of that party, the local ward member personally opposed the proposal because of his fears for the repercussions on the local golf club, of which he was a member. Party allegiances prevented him from speaking out in opposition to the scheme, but nevertheless he deliberately avoided constructive dialogue with the development team. A better understanding of the councillor’s view at the early stages of the consultation would have enabled the team to communicate more effectively with the individual.
Stakeholder and political research tends to be interlinked, as local politicians are inevitably significant players in the local community. Similarly, communities of interest and communities of place co-exist (exacerbated by the increase in online communities) and most individuals fall into a number of categories.
Special interest groups are easy to identify, but thorough, ongoing, stakeholder research is necessary to identify less formalised groups and patterns of interest. Comprehensive stakeholder and political research enables a much better understanding of those likely to take part in the consultation, and importantly, unearth useful and relevant insights. Typically the exercise will identify the following:
The demographic profile of the area
Local organisations – from community organisations to businesses and the issues affecting them
Community / political / religious and special interest groups, their leadership, membership, policies and influences
The political make-up of the council
Planning committee members and ward members
Political movers and shakers, including those with informal influence both within the council and in the wider community
The likely impact of any upcoming elections on both the political make-up and individual roles
Historic planning applications, particularly those for the site in question, or similar proposals which have been considered previously
Likely attitudes towards the development proposals among these stakeholders
The history of local opinion towards proposed developments for the site, if any
Frequently stakeholders are prioritised using a matrix approach. Such an approach will plot power in one axis and interest in another (either may be substituted with location or any other relevant factor for measuring likely involvement), thus using the matrix to determine the prime focus for the consultation.
The various methods of stakeholder mapping and research available have the potential to depict the community as an eco-system, assessing the potential power and influence of individuals on a matrix and their known reaction to certain issues. This enables the development team to assess a specific individual’s potential view (be it positive or negative) and asses the influence of that view within the consultation.
At the end of the research process, the team will have an excellent understanding of the community generally, the personalities and groups which shape it and the issues which motivate or antagonise it. It should become clear which sections of society are likely to respond to the planning application. Information relating to key stakeholders, their contact details and relevant influences and opinions can be collated either in the form of an Excel database or held on Customer Relationship Management (CRM) software. Stakeholder engagement software is often used for larger projects as it has similar functions to CRM systems but can be customised to a specific project. It enables individuals to be pin-pointed geographically and provides data distribution and analysis. The database should be continually developed, expanded and maintained throughout the consultation process.
In 1969 the US communications academic Sherry Arnstein identified the terminology of consultation in her Ladder of Participation. In some respects, Arnstein’s theory is a useful resource by which community involvement can be considered today.
Arnstein’s Ladder was intended to reflect the relationship between community and government, identifying poorly-led participation as ‘manipulation’ on the bottom rung of the ladder and rising to ‘citizen control’ at the very top.
My first reflection on this, along with many other consultation professionals, is that ‘consultation’ is rarely ‘tokenism’.
The dynamic process of dialogue between individuals or groups, based upon a genuine exchange of views, with the objective of influencing decisions policies or programmes of action.
It is dialogue, it is two way, and it seeks to gain feedback in order to inform decisions.
Furthermore, I think that most developers quite justifiably choose to ignore the top two rungs of the ladder – the best consultations are a partnership between a developer and the community, not a relinquishing of control to the community.
I also suggest alternating the positions of consultation and placation, thereby positioning consultation at the centre of the ladder, representing a process which involves local people and government / organisations equally. Ideally the fifth rung would be divided further to reflect the fact that consultation itself has many forms as shown below:
This, I hope provides a more up-to-date framework by which consultations can be considered.
Today is the deadline for responses to the Government’s consultation on its policy paper Planning reform: supporting the high street and increasing the delivery of new homes, which proposes to increase the Permitted Development Rights allowing change of use, and in doing so removes public consultation from decisions affecting the regeneration of town centres.
I have responded to this consultation on behalf of The Consultation Institute’s Planning Working Group. While we fully support diversity on the high street, along with provision of much needed housing, we strongly object to the assumption that this can be achieved successfully without public engagement.
The consultation suggests that new ‘temporary’ permitted development rights are granted; but also that previously ‘temporary’ rights are made permanent. It would not be unduly presumptuous to assume that (with or without a Government consultation to aid the decision) these new ‘temporary’ rights will themselves become permanent in time. Again, tCI is strongly opposed to this proposed change.
The consultation comes at a time when the importance of strengthening consultation has been correctly recognised by the TCPA in its recently published Raynsford Review (read my commentary on the Raynsford Review here). Both the TCPA and the RICS have opposed the extension of permitted development rights.
A sample of my responses to the consultation:
Do you agree that there should be a new permitted development right to allow shops (A1) financial and professional services (A2), hot food takeaways (A5), betting shops, pay day loan shop and launderettes to change to office use (B1)?
No. Change of use to this extent would substantially alter the face of the high street and should not go ahead without consultation with those most affected – ie, the local residents. PD Rights exclude consultation and therefore are an inappropriate tool for such a decision. Local people should be consulted on the future of their communities. Furthermore, it is to be benefit of the organisation providing / running the new facility to understand reactions to it from within the local community.
Do you agree that there should be a new permitted development right to allow hot food takeaways (A5) to change to residential use (C3)?
No. While tCI supports the introduction of more housing and the enlivenment of our high streets, we consider a change of use of this magnitude – one which would conflict with the Local Plan’s allocation as well as the original planning consent – should not be carried out without consultation. It could be argued that a Local Plan or Neighbourhood Plan is of little value if uses can be changed despite an original allocation, and changes to allocations which have previously been arrived at following planning consent could result in local residents becoming less inclined to respond to Local Plan consultations.
Do you agree that the permitted development right for the temporary change of use of the premises listed in paragraph 1.9 should allow change to a public library, exhibition hall, museum, clinic or health centre?
No. Any change to the built environment impacts on communities, and this is particularly true in the case of libraries, museums, health centres and other amenities. At the heart of our planning system is an understanding that those proposing change should involve local residents – not just as a courtesy but because developers also have much to benefit from involving local people in terms of how the new facility will be used. With local input, proposals can be enriched and finely tuned to a specific neighbourhood, creating a unique scheme well suited to its location. The local community, too, can benefit from consultation: community involvement can promote social cohesion, strengthen individual groups within it and create a shared legacy. This should not be overlooked, particularly in the case of providing public facilities.
We are also concerned about the use of the word ‘temporary’ is used in this context. Several of the previously temporary uses are now potentially becoming permanent and it is particularly concerning that permanent change should not occur without consultation.
Do you think there is a role for a permitted development right to provide additional self-contained homes by extending certain premises upwards?
No. The principle should be consulted upon because it could have a substantial impact on the local community. If regulations concerning upwards extensions are to change, we would expect this to be reflected in local policies. Therefore the local authority should consult (either as part of its Local Plan or separately) on the policy change? If the local policy does not change, tCI believes that consultation should take place on a case-by-case basis.
Do you agree that the existing time-limited permitted development right for change of use from storage or distribution to residential is made permanent?
No. Local people should be consulted on such substantial changes. Additionally serious concerns have been raised (by the RICS and the TCPA among others) about the quality of such accommodation and the risk it poses to those living there. It is not in the public interest to retain sub-standard accommodation and to give permanent consent to something which was only intended to be temporary. This is detrimental to both the residents and the wider community.
Do you agree that the time-limited permitted development right for larger extensions to dwellinghouses is made permanent?
No. Local people should be consulted on such changes. Furthermore the proposal to make permanent temporary rights is undemocratic because permission was not originally granted for a permanent change. Changes such as this reduce public confidence in the planning system. Ultimately the public could understandably be mistrustful of any temporary rights being granted in the future if it was felt that such rights could be made permanent in such a way.
Do you support a permitted development right for the high quality redevelopment of commercial sites, including demolition and replacement build as residential, which retained the existing developer contributions?
No. This would be a very significant change: currently commercial to residential change of use is only allowed under PD rights because the exterior of the building does not change. If an office building was to be demolished and housing developed in its place, we believe that consultation is required.
Many communities lack commercial space, which results in higher levels of unemployment, unsustainable outside of the area, and traffic congestion. Although we have a housing crisis, there should not be a general assumption that homes are needed in place of commercial use.
Change of use for an entire site – as opposed to a single unit – represents a substantial change to a local community and one which should not take place without consultation. Assuming the Local Plan had previously allocated the land for commercial use, it would also contradict the Local Plan. This both risks lowering the public’s faith in local democracy and will inevitably discourage local people from taking part in local authority-led consultation (or indeed any planning consultations) in the future.
What considerations would be important in framing any future right for the demolition of commercial buildings and their redevelopment as residential to ensure that it brings the most sites forward for redevelopment?
Consultation with local people. The advantages of developer consultation are numerous. Consultation can deliver a real insight into a local area, create enduring beneficial relationships and enable an early understanding of any issues or misunderstandings which may stand in the way of planning success, thus save time and money.
In 2011, the Department for Communities and Local Government’s Localism Bill stated that, ‘Pre-application consultation provides an opportunity to achieve early consensus on controversial issues before proposals are finalised. This should encourage greater community engagement in the process, and result in better quality applications submitted to local authorities, which are more in line with community aspirations, and much less controversial. Such an approach is considered to be inclusive and transparent, with development outcomes more in line with what the community desires.’ We would hope that the MHCLG still subscribes to this point of view but this consultation would suggest otherwise.
For any builder involved in development projects, communication with local residents usually starts during the planning process. But it doesn’t end there.
Once you’re on site, the immediate community, local groups and potential occupants will all want to understand what’s being built and the timescales involved. They’ll be the first to complain about bad parking, dust and noise. They’ll say that no one is telling them what’s going on. They could even affect your chances of getting planning permission next time.
So all builders will benefit from gaining the goodwill and support of local residents, and possibly the local media too, and this can only be achieved through good communication.
Traditionally, community relations during construction has largely been managed through newsletters and public meetings. But as our use of the internet increases, the old, often expensive and time-consuming methods of communication can be partially replaced by something much simpler and more effective: a community relations website.
A typical community relations website may include a timeline for the development, an interactive map, Q&As (to which users may contribute), the Construction Management Plan, regular updates on construction work and images. Time lapse photography is very popular, as are CGI fly-throughs of the future development.
Other useful information might include an introduction to the development team and all its corporate social responsibility initiatives such as apprenticeship schemes. External links, such as to the Considerate Constructors Scheme, are also popular.
Finally – but perhaps most importantly – a website offers the opportunity for users to register their interest so they can get the information they want, be it on property sales, lettings or employment opportunities.
Our research has shown that online community relations appeals particularly to the under 40s, to working parents and to commuters. Many so-called ‘hard-to-reach’ groups can also find what they are looking for best through a website thanks to the physical accessibility of the internet and the opportunity to use automatic translation, large text and text-to-speech technologies.
Online communication has the advantage of being available 24/7. Residents most frequently view our clients’ community relations websites late at night, and construction companies benefit from being able to communicate immediately with residents when required.
Of course online community relations will never replace the power of face-to-face communications. Knocking on doors and talking to neighbours is still the best thing to do, and a screen will never compensate for a human face.
But when the diggers arrive on site, most people will head straight to Google to get the information that they feel entitled to know. Rather than allow residents to become frustrated at that crucial first point of contact and resort to social media and chat rooms to speculate about the changes to their neighbourhood, the savvy builder will use this opportunity to provide a first impression that is welcoming and informative and establishes the new development in the very heart of the community.
Original first published in Master Builder Magazine, December 2018 following a presentation to the FMB annual conference by Liz Male of Liz Male Consulting and Penny Norton of PNPR in September 2018.
The final report is an incredibly comprehensive and significant assessment of the English planning system by former housing minister Nick Raynsford and the product of thousands of responses, including my response on behalf of the Consultation Institute (which can be viewed here)
The Review warns that planning has been reduced to a ‘chaotic patchwork’ of responsibilities which is not compatible with promoting the health, wellbeing and civil rights of communities.
It finds significant deficiencies in community involvement, which, it states, is ‘incompatible with the basic principles of democracy’ and in which ‘people’s involvement in planning is no longer characterised as due process but as delay’.
More specifically, it cites social media, ‘fake news’ and well-resourced campaign groups (the cause of ‘a toxic political environment’) as being barriers to sensible debate, along with ‘a lack of support services for communities on planning applications and Local Plans’, the power of developers to exploit and dominate the planning system, complex language and procedures, a lack of community engagement skills among planners, unequal legal rights which reinforce the perception of a system constructed to benefit applicants, anger that decisions seemed to ignore community concerns and anger at the perceived ‘purchase of planning permission’ through Section 106 agreements – among others.
It also states that blanket descriptions of the ‘public’ or ‘community’ can mask the diverse and sometimes competing needs and aspirations of complex social groups.
The Review calls for a more positive, ‘people-centred’ and ‘sociable’ planning system. It makes many recommendations which chime with PNPR and the Consultation Institute’s own thinking on consultation in planning. The recommendations include:
A renewed focus on planners’ skills
A policy statement on people and planning
A new covenant for community participation, based on:
democratic accountability
clear citizen rights
a significant new approach to helping communities to engage in the planning process
a new professional culture and skills set directed at engaging communities.
A new commitment to meeting people’s basic needs and rights, including:
a duty on local authorities to provide genuinely affordable homes
a right to basic living conditions to support people’s health and wellbeing, secured through minimum national design standards which meet people’s needs throughout their lifetime
a legal obligation to plan for the needs of future generations, by, for example, the consideration of resource use.
Community powers to plan effectively – giving communities and local authorities the powers they need to shape developments which have a real impact on people’s safety, health and wellbeing
A new legal duty to promote the Aarhus Convention rights
Improved public awareness of planning, through harnessing the benefits of new technology, redirecting resources to general planning advisory services, establishing a community planning portal to act as a hub of community resources on planning, work with the Department of Education to embed planning skills in the national curriculum as a key part of citizenship, and harnessing the resources of the planning schools to support community understanding and empowerment.
On behalf of the Consultation Institute, I am working increasingly closely with the TCPA on strengthening community involvement in planning. I was recently asked to attend a roundtable discussion on Empowering Communities to Participate in Planning for New Communities and have been involved in the drafting of a new TCPA guide People, Planning and Power which is published in March 2019. Additionally I have offered its support to the TCPA in a variety of areas, including the drafting of new covenant for community participation and code for consultation in planning, advice on how to restore the disconnect between planning and people and in overcoming apathy. We hope that over time more developers and planning consultants will use tCI membership to raise standards in planning consultations.
Whether Nick Raynsford’s recommendations are taken on board very much depends on how political events play out over the next few very uncertain weeks. But there is certainty in that these are constructive recommendations which have the potential to transform both attitudes and outcomes people’s role in planning.
I am frequently asked whether consultation is a legal requirement in planning. The fact that it is impossible to answer in fewer than 100 words exemplifies just how complex community involvement in planning has become.
And so I, and other Associates of the Consultation Institute, very much welcome the Interim Report of the Raynsford Review and the very constructive steps that it recommends in bringing about greater clarity and consistency.
Members of the Consultation Institute’s Planning Working Group – all communications / planning professionals working in planning and development – have considered the Report’s recommendations and their potential implementation. Although there is no expectation that the nine propositions will result in immediate changes to planning law, much of what is recommended, along with our commentary on them, might be regarded as good practice and therefore is worthy of consideration by planners and developers.
A historic need
Despite growing concern about public disaffection in the planning system, there has been no comprehensive review of the relationship between planning and people since the 1969 Skeffington Report. The Report received a positive reception, but few of its recommendations were put into practice – apparently because they were too vague and intangible. And yet the Skeffington Report had an enduring influence on community involvement in planning – to the extent that Skeffington is said to have influenced the introduction of Localism over forty years later.
In 2011, embarking on the Localism agenda which was to set the scene for community involvement in planning today, the Government said:
‘Pre-application consultation provides an opportunity to achieve early consensus on controversial issues before proposals are finalised. This should encourage greater community engagement in the process, and result in better quality applications submitted to local authorities, which are more in line with community aspirations, and much less controversial. Such an approach is considered to be inclusive and transparent, with development outcomes more in line with what the community desires.’
The statement was based on research carried out by the then Department for Communities and Local Government which found that as a result of pre-application consultations there was a 10-15% fall in the number of appeals, hearings and enquiries. Additionally, a YouGov poll for the National Housing and Planning Advice Unit had demonstrated that 21% of respondents opposed new housing supply in their area, but that this number fell to 8% if homes were well-designed and in keeping with the local area.
Localism (which was itself instigated by the need to substantially increase the UK’s housing stock) was based on the belief that local involvement would deliver greater consensus. In an environment in which local comment on development proposals was generally negative, this was a bold approach and one which should have begun by communicating the benefits of consultation in bringing about appropriate development. Unfortunately the Government – unlike Raynsford – failed to do so.
The eventual Localism Act was significantly less bold on the requirement for consultation than it had originally intended: while the Bill set out to enshrine a requirement to consult in law, the Act omitted the requirement to consult on planning applications in England and Scotland with the exception of planning applications for wind turbines.
And so while there are considerable obligations for local authorities to consult on the formation of a Local Plan, for Neighbourhood Plans to be determined by referendum and for NSIP applications to follow a very prescriptive consultation strategy, there is little requirement on the average developer to consult, other than some vague wording in the NPPF (regrettably unchanged in the 2018 revisions) which states that, ‘Early engagement has significant potential to improve the efficiency and effectiveness of the planning application system for all parties’ and that ‘Good quality pre-application discussion enables better coordination between public and private resources and improved outcomes for the community.’
In a further watering-down, the NPPF continues… ‘Local authorities… cannot require that a developer engages with them before submitting a planning application, but they should encourage take-up of any pre-application services they do offer,’ and ‘Where they think this would be beneficial, encourage applicants…to engage with the local community before submitting their applications.’
So the legal requirement for consultation in planning remains vague and widely misunderstood, and the work of the Raynsford Review in demystifying this is much welcomed.
Enriching planning through community involvement
While the legal requirement for developers to consult remains opaque, the notion that community involvement can benefit planning decisions is unequivocal.
Planning is ultimately about people: whether a local authority-run strategic plan or a private sector-led development proposal, change to the built environment impacts on communities. While it is generally believed that those proposing changes should involve local residents as a courtesy, additionally planners and developers have much to benefit from involving local people.
Consultation provides the opportunity to glean information and ideas from a local community. This might include knowledge of local history and which has the potential to enrich a scheme, otherwise unknown social issues which might have delayed the process, and the needs and aspirations of the community which may be met through the new development. With local input, proposals can be enriched and finely tuned to a specific neighbourhood, creating a unique scheme well suited to its location.
The local community, too, can benefit: community involvement can promote social cohesion, strengthen individual groups within it and create a shared legacy.
Following local dialogue at an early stage and having had proposals either challenged or welcomed, a developer has a greater chance of building local support for a proposed scheme. And a well-run consultation can build a trusting and mutually cooperative relationship between the developer and the community, which can minimise the potential for conflict and thereby remove risk in the process.
Clarification in a covenant
So it is without hesitation that the Consultation Institute supports the Raynsford Review’s call for greater clarification on the role of community engagement in planning.
Specifically, we welcome the proposed covenant for community participation which has the potential to formalise requirements for consultation in appropriate circumstances, rectify the uncertainty about when a developer is required to consult and clarify the expectations that local communities should have of the planning system.
Such a covenant would require clear definitions of consultation / participation / involvement / engagement and the circumstances in which each should be used. All too frequently the terms are used interchangeably at considerable risk to the developer or planning consultant. ‘Engagement’ and ‘participation’ refer to an ongoing, generally long-term dialogue and can vary significantly. ‘Consultation’, however, as a result of considerable case law mostly outside the development sector, has become very litigious. Specifically, the courts view consultation in the context of the Gunning Principles and where these are not upheld, decisions can be overturned by the courts.
Similarly, the ‘three pillars’ (Articles 4-9) of the Aarhus Convention (named after the location of 1998 United Nations’ Economic Commission) stipulate three public rights regarding access to information, public participation and access to justice in governmental decision-making and, like the Gunning Principles, have become an important benchmark in consultation, specifically in relation to dialogue between the public and public authorities.
The Consultation Institute hopes to work with the TCPA on a draft covenant for community participation and, as the Interim Review recommends, would use both the Gunning principles and those of the Aarhus Convention as its basis.
Raising standards and encouraging innovation
We also see the final report of the Raynsford Review as an opportunity to raise standards in consultation. Specifically, a renewed focus on consultation can put in place measures to ensure that dialogue is efficient and meaningful without being excessive, ensure that involvement of a wide range of groups in the local community, and put in place some guidance on how consultation results are used. The latter does not simply concern issues with evaluation, analysis and reporting (though there are certainly opportunities for improvement at this stage), but also the need, at the start of any local dialogue, to agree and clarify how feedback is to be used.
Confusion on this issue is unsurprising. In the case of a Neighbourhood Plan, a local referendum determines the final decision, yet community responses to a development application are generally only regarded as ‘advisory’ and secondary to that of the professional team. Consequently local communities remain confused about the intended use of their contributions and this is a primary reason for dissatisfaction in the current system.
Promoting community involvement as a central tenent of planning, one that is structured by guidelines and inspired by best practice, has the potential to tackle many of the issues that continually perplex planners and developers.
While the Consultation Institute is a strong advocate of good consultation, we do not prescribe consultation in all circumstances. Each development proposal is different: some benefit from community input from the very outset, while in other cases viability issues prevent community involvement in all but a handful of decisions. We believe that where consultation on a planning application is appropriate, it should be efficient and meaningful, without being excessive and a selection of means by which this might be achieved is summarised below (Efficient and meaningful consultations).
The proposal for ‘a new professional culture and skills set directed at engaging communities’ is long overdue. Planning consultants and developers are generally highly trained, their undergraduate and postgraduate degrees covering a wide spectrum of skills. With only a few exceptions, however, consultation has so far featured on very few syllabuses. In fact when I published my book Public Consultation and Community Involvement in Planning: a twenty-first century guide last year, it was the only book on consultation in planning to have been published since the Skeffington Report almost fifty years earlier.
Through other generally more litigious sectors, the Consultation Institute has contributed to a professionalisation of consultation through quality assurance, consultation industry standards of practice, professional accreditations and CPD and we see considerable benefit in these benefits applying to the development sector.
Similarly, the Consultation Institute is fully supportive of the Interim Review’s proposition for a new ‘creative and visionary’ planner. We see some excellent examples of creativity and innovation in consultation – both within the planning sector and elsewhere – which could be communicated more widely across the planning sector and inspire more positive community engagement.
We look forward to the publication of the Raynsford Review, and with it the development of the very many positive ideas that are contained within the Interim Report. As a next stage, we see significant benefit in guides on consultation in planning for both the development industry and for local residents; the creation of a ‘good’ consultation kitemark for the industry; training for planning consultants on consultation, and a formalised means of best practice across industry, specifically on subjects such as online consultation, evaluation and analysis, the use of co-production and participatory planning.
There is no doubt, as the Interim Report acknowledges, that it is, ‘a challenge to define how much power communities should have as compared to the development industry or national Government’. Striking a balance between achieving growth and giving existing communities a voice is a perpetual problem, but one which can be lessened and in many cases overcome through an appropriate and considered approach to community consultation.
The Gunning Principles
Consultation must be held at a formative stage, so that respondents have maximum opportunity to influence decision making.
Consultation must provide sufficient opportunities for ‘intelligent consideration’, so that respondents can come to informed opinions.
Consultation must provide adequate time for consideration and response, to ensure that respondents have sufficient time to come to and express a view, and that there is sufficient time to properly consider that view.
Consultation must ‘conscientiously consider’ feedback received.
Efficient and meaningful consultations
Consultation strategy
Gain a thorough understanding of the target consultees, especially any ‘hard to reach’ groups.
Determine how consultation responses will be used at the very start of the process. If community feedback is to advise, rather than determine the resulting decision, this should be clearly stated. It is also helpful to state how anonymous responses, petitions and comments from outside any defined geographical area should be used.
Where possible, meet with community support / neighbourhood involvement officers to discuss how to ensure effective access for hard to reach groups.
Carry out initial research including stakeholder and issues analysis.
Draft a consultation mandate, stating the target audience, the aims and objectives of the consultation, the subject for discussion, how the results will be used, the organisation initiating the change post-consultation and its timing. Ensure that the consultation mandate is communicated effectively, including on all consultation material.
Timing
Hold the consultation at a formative stage, so that respondents have maximum opportunity to influence decision making.
Provide adequate time for consideration and response (both in the consultation and the analysis of it).
Avoid a clash of consultations – for example, consulting on a development planning application during a Local Plan consultation.
Allow no fewer than six weeks for a standard consultation; more if a significant holiday period falls during this period.
Selecting tactics
Ensure a range of tactics to appeal to the range within the community.
Consider all tactics in terms of access – both physical and psychological.
Consider innovative tactics to make the consultation more engaging.
Use a variety of tactics to inspire involvement.
Consider tactics most likely to result in constructive responses.
Understand the specific groups that make up the neighbourhood and ensure that consultation tactics are targeted suitably, investing in translations if necessary.
Determining questions
Provide adequate information to enable consultees to make a fully informed response.
Combine both quantitative and qualitative research techniques as appropriate.
Ensure that questions and accompanying information are free from technical jargon.
Analysis, evaluation and feedback
Evaluate the consultation responses as set out at the start of the consultation.
While the property world is being transformed by PropTech, a comparison between most developer-led consultations with those of the late twentieth century would suggest that little has changed: today’s consultations appear to rely on newsletters, exhibitions and paper surveys, just as they did then.
And yet innovative and effective communications tools exist, and have the potential to revolutionise consultation.
It was the absence of accessible best practice in modern methods of communication that led me to write Public Consultation and Community Involvement in Planning: a twenty-first century guide. The book shows how consultation has moved with the times and the planning process is has benefitted as a result.
Changes in the world of communication
The communications revolution has brought about an explosion of data (from ‘big’ and extremely detailed), unparalleled access to information, opportunities to reach millions at the touch of a button, improved dialogue, non-hierarchical communications, more agile research tools, and significantly improved means of analysis.
Internet usage is increasing year on year. In 2016 no fewer than 99.2% of adults aged 16-24 were recent internet users and although the older population has some way to go before it reaches saturation point, it is the fastest growing group.
The way in which we use the internet also continues to grow and diversify. 61% adults use social media and 70% regularly access the internet using a mobile phone or smartphone – double the proportion five years previously. Technological changes have, without doubt, had the greatest impact on communication so far this century.
The American University Center for Social Media has identified five categories of internet usage: choice, conversation, curation, creation, collaboration. In a planning context, these behaviours might be described as follows:
Choice: seeking information on Local Plan formation, policies and planning applications though search engines, recommendations, news feeds and niche sites.
Conversation: discussing proposed schemes on forums, blogs and microblogs; taking conversations into new forums (such as those of special interest groups).
Curation: selecting and linking to content to form arguments targeted at specific groups; posting and reposting
Creation: developing new content such as a film to communicate a specific point of view
Collaboration: building support for a campaign.
As the capabilities of the internet grow, the opportunities for involvement within each of these categories will increase and individuals’ behaviour online will become increasingly powerful.
The communications revolution in planning
The internet has had a huge influence on planning, perhaps more so than any piece of legislation. And unlike legislation, the surge in online communication cannot be reversed.
Following the ‘digital by default’ transformation programme and the establishment of the Planning Portal, central Government communications on planning is primarily online; similarly all Local Plan and planning application consultations are hosted online by local authorities, and with the rise of ‘hyperlocal’ websites and online campaigning, stakeholder groups connected to planning decisions can communicate online very effectively.
Developers opting not to have an online presence, or those who install a website with no mechanism for dialogue, run the risk of their scheme being debated on closed blogs and Facebook groups and consequently will be unaware of any mounting objection until it becomes too late.
The benefits of online consultation
Access and engagement
Currently 12% planning applications fail to gain planning consent because of issues related to consultation and community engagement.
By targeting residents via their preferred means, the likelihood of widespread engagement and support is increased. Users can take part in an online consultation where they want – at home or on the move and when they want. 79% ConsultOnline users take part in consultations using smart phones or tablets and a large proportion respond late at night.
Online consultation has the power to reach new audiences – particularly the young and the time-poor. The average age of residents taking part in an online consultation is 35 – 44: typically young parents who work, perhaps commute, and have little time to attend evening meetings.
Removing hierarchies
In a busy public meeting, attendees frequently defer to a dominating character or group leader; whereas online, individuals are more likely to voice their opinions without fear of repercussions.
A wide selection of dialogue methods
There is no single ‘right’ method of consultation and given the range of stakeholders in any one community, a variety is always beneficial.
The internet has enabled the toolbox of consultation techniques to be expanded considerably as these examples show.
Appropriate timing
The days of informing the public on a development proposal and collating results at the end of the process is over. Online communication is ongoing, fast and responsive, enabling the consultor to become aware of, to understand, and to correct any misconceptions immediately.
Proactive use of the internet by the development industry
Among those developers who understand the benefits of online consultation, usage generally falls into one of three categories:
Consultation via social media – most commonly Facebook, Twitter and Instagram
Consultation using ‘off the shelf’ consultation websites such as Citizen Space, E consult and Community Tools
Consultation using specially developed consultation websites put in place by the consulting organisation (sometimes as microsite attached to an existing website).
ConsultOnline
A comprehensive website and consultation service which combines the features of social media with additional functionality
Uses wide-ranging and innovative tactics to inform and consult
Updated regularly throughout the consultation
Enables access to polls and forums on the basis of a specific postcode area
Users view a computer generated 3D digital model of both the development site and the surrounding area (which is updated to incorporate the proposed development)
Users identify specific locations on a map and view the 3D model from these locations
The position of the development can be viewed on Google Earth from selected locations, both as an aerial image and in Streetview.
Virtual reality (VU.CITY)
The first ever fully interactive 3D digital model of London
Users can visualise proposed developments within the existing context of the city
Users can embed transport data, overlay sightlines, identify transport links and sun-light paths and, from street level, help consultees understand the proposals in context
The London View Management Framework is used in relation to protected views and can search existing, consented and planned developments.
Users develop hypothetical visions of a development area using popular games such as Minecraft and Second Life.
Research and analysis
The internet has brought about a research renaissance. It has enabled detailed research to inform consultation strategies, create an understanding of local communities and ensure that appropriate dialogue methods are selected. Stakeholder mapping literally ‘maps’ a community, assessing the power and influence of individuals and gauging their likely reaction to specific issues.
A more scientific approach has also been taken towards monitoring, analysis and evaluation. The ConsultOnline model allows all data collected, from comments in meetings or in writing to online polls, to be processed through a consultation website, facilitating up to date consultation reports as required, at the touch of a button. It is hard imagine that previously the developer would have had little knowledge of resident sentiment until the end of the consultation. Today, we have the tools to easily identify emerging themes, possible misapprehensions and potential ‘ambassadors’.
There is undoubtedly some every effective innovation in the planning world, but modern methods of communication are far from universal.
Of course online consultation cannot replace offline consultation entirely until 100% of any local community is able and willing to communicate online. To some, a screen will never compensate for a human and for that reason face-to-contact should remain. However, there are many advantages of online consultation: it is popular and accessible, time and cost effective, clear and uncomplicated; information can be immediately available and discussions open to all, and evaluation is substantially more sophisticated than previously.
It is important that the planning world doesn’t lag behind the communications abilities of the stakeholder groups with which it communicates. Today’s young adults have grown up with Facebook, Survey Monkey and 38 Degrees, and as such are effective online communicators. Inspiring them play a constructive role in planning, while also keeping up to speed with the various interest groups which have an ever-increasing role to play, requires the development industry to accept and adopt change enthusiastically.
From the first planning meeting to the last construction vehicle leaving site, building benefits from positive communication with local residents. And as the way in which people’s approach to communication changes, so too should the construction industry’s.
The internet is changing communication in every context. Today over 90% households have internet access, 73% adults own a smart-phone and online is increasingly the preferred method of communication for many community groups.
Planning authorities are now required to post applications online, local residents discuss and debate development proposals via social media and in blogs, and the media gathers these views to inform news stories. Once the diggers arrive on site, local residents will head online to get the information that they feel entitled to know.
So no new scheme is without an online presence – irrespective of the developer’s intentions. And rather than allow chat fuelled by speculation and misinformation to dominate the online presence, savvy developers and construction companies are finding that websites present a great opportunity to communicate efficiently and cost effectively.
Whether in consultation or community relations, online communication should not take the place of offline communication, but can complement and enrich it. It can also reduce offline communication, and therefore overall costs.
In using online consultation in planning, I have found that communicating with residents via their preferred means significantly increases support. And the same is true of community relations during construction: when targeted via their preferred means of communication, people are more supportive of a scheme and understanding of any disruption.
Local residents appreciate online communication because they can get involved when and where they want, while technology can assist in making communication physically accessible for those who might find other forms of communication difficult.
Construction websites can convey a substantial amount of information about the scheme and its timeline, and provide links to newsletters which would otherwise be expensive to deliver to a wide area. A database of local residents who wish to be kept informed of progress provides a means for the contractor to get in touch easily and quickly regarding any road closures and major work on site.
A community relations website may include a timeline, interactive maps, Q&As (to which users may contribute), regular updates on construction work and images. Time lapse photography is very popular, as are CGI fly-throughs. Other useful information might include an introduction to the team with hyperlinks to each organisation’s own website – a great opportunity to inform local residents of sustainable features, commitment to using local workers / suppliers and other corporate social responsibility initiatives such as apprenticeship schemes. External links, such as to the Considerate Constructors Scheme are also popular. Perhaps most importantly, a website offers the opportunity for users to register their interest under a range of subjects, be it in relation to construction updates, sales and lettings or employment opportunities.
I am increasingly working with construction companies to develop and administer community relations online, which takes the day-to-day responsibility for local resident communication off the shoulders of the contractor in a way that is time (and therefore cost) efficient but also reassures the local authority that they have a dedicated service.
As communication increasingly moves online, so too will our contact with local residents. To some, a screen will never compensate for a human face and for that reason face-to-contact should remain. However, there are many advantages of online communication: it increases accessibility, it is clear and uncomplicated, and information can be readily available and visible to all. And using a website and social media alongside traditional means can reduce cost and time expenditure by half. It is no surprise that the development industry is increasingly choosing to communicate online.
Try to envisage a world without Local Plans, the NPPF, Neighbourhood Planning, Localism and CIL and its clear quite how much planning has changed in the last ten years. And the same is true of communication: not only the means by which we communicate but also the manner in which we communicate.
The extent of this change led me to write Public Consultation and Community Involvement in Planning: a twenty-first century guide, which was published by Routledge in July. This article explores some of those changes and provides some practical advice on their implementation.
Collaboration in place of conflict
A decade ago, consultation was dominated by the dreaded public meeting. A development team would prepare a masterplan to support a planning application and, bearing down on them from a podium, tell a large group of local residents what was intended – ideally for long enough to minimise comment. But disgruntled locals were invariably present, quick to jump to their feet and oppose the scheme, and rally their neighbours into an angry frenzy. Generally residents would attend only if they objected – what was the point in venturing out to a draughty village hall if you were broadly in support of the proposals? And the local media would attend in anticipation of a dramatic evening, which often resulted in a harmful news story.
Not all public meetings took this form of course: many were constructive and they continue today in some circumstances. But generally, development teams now seek more engaging and constructive means of consultation.
Participatory planning – also referred to as community planning, community visioning or collaborative planning – is gaining increasing prominence, its engaging approach providing a welcome alternative to the adversarial public meeting.
The process of participatory planning varies, but typically it involves pre-engagement research and dialogue; a community planning day in which groups of residents, assisted but not directed by professionals, create visions and solutions which they then feed back to the larger group; development of a masterplan by professionals following local insight; followed by an exhibition at which the masterplan is formally consulted upon.
The benefits of this approach are substantial. Early engagement can create a sense of ownership among the community, build trust with the development team and result in positive sentiment towards change. Participatory planning, because of its variety of tactics and emphasis on facilitation, can involve a range of local voices including those who would not choose to comment otherwise. The process frequently accelerates the masterplanning process, partly because it involves not only local residents, but also politicians and planners too.
Participatory planning is only effective if a considerable amount of time is invested at an early stage, providing an opportunity for the community to be involved in developing a vision, and it requires considerable faith and an enlightened attitude on the part of the development team. But of those who have taken the plunge, the vast majority would take every opportunity to do so again. In fact that this form of consultation has flourished in every sector, from Neighbourhood Planning to large scale mixed use schemes.
Research renaissance
As communication has become increasingly strategic, the importance of research in informing the choice of tactics has increased.
It is common for a consultation team to compile a consultation strategy internally, using research gathered informally from a variety of sources. However, in line with the increasingly collaborative approach to consultation, local residents are increasingly engaged in dialogue during the very early stages of consultation.
Then, as a consultation strategy is developed, the role of research switches to that of stakeholder information and analysis. Researching likely consultees enables the consultation strategy to take into account the appropriate number of residents to be targeted, the diversity within the community and an understanding of where power lies. Without it, a consultation runs the risk of being asymmetrical and failing to reach certain sections of the community, which often includes the ‘silent majority’ as well as the traditionally hard to reach.
A recent innovation, stakeholder mapping is proving extremely constructive. It provides the potential to depict a community as an eco-system, assess the power and influence of individuals and gauge their likely reaction to specific issues. It allows the development team to understand an individual’s likely view (be it positive or negative) and can assess the impact of that view on others being consulted.
Stakeholder engagement software enables the pin-pointing of individuals geographically and provides data distribution and analysis. This resource is most useful when maintained and continually expanded upon. However it should be used only for the purpose of the consultation and data protection rules adhered to, all the more so with the introduction of new General Data Protection Regulations in May 2018.
Developments in monitoring, analysis and evaluation
Monitoring, analysis and evaluation are important elements of strategic consultation. Monitoring occurs throughout; analysis, although it can be on-going, takes place (or is complete) at the end of the process; and this is followed by evaluation.
It goes without saying that electronic communication has enabled a more scientific approach to each. I recently ran a consultation in which all data collected, from comments in meetings to online polls, was fed through a consultation website, enabling me to present the client with an up to date consultation report as often as required, at the touch of a button. It is hard imagine that previously the developer would have had little knowledge of resident sentiment until the end of the consultation: today, issues management is a key strategic element of any consultation and we have created the tools to easily identify emerging themes, possible misapprehensions and potential ‘ambassadors’.
With the move towards participatory planning, consultation data has moved from being predominately quantitative to predominately qualitative. Qualitative data – observations and comments, usually expressed in words rather than in numbers both provides a context for quantitative data, and enables the consulting body to get to the heart of an issue. And again, recent technological developments have brought about a more effective means of measurement.
The online consultation revolution
The increased popularity, power and availability of the internet accounts for much of the change in public consultation over the past two decades. This increased significantly in 2004 when Web 2.0 enabled more effective two-way communication. The rise in individual and community use of the internet, combined with the requirement in 2005 that local authorities and other public bodies ‘e-enable’ all services including planning, public involvement and consultation, means that all development proposals have an online presence – whether intended by the developer or not.
There are many reasons why developers increasingly choose to use online consultation:
Research: The internet is by far the most powerful research resource. A substantial proportion of information that is required in researching stakeholder groups and necessary background information is freely and readily available.
Issues management: A constructive consultation is based on the community having access to reliable information, which can be easily sourced online. Monitoring of online consultation provide an immediate and effective means of understanding local sentiment and identifying any misapprehensions.
Immediacy: Online consultation has the advantage of being immediate: information can be posted and responded to in minutes. But consultation timelines should not be shortened as a result. On the contrary, immediate communication can only take place if the audience has been targeted and is in receipt of the message. Online communication can potentially spread quickly but only if the message is strong and compelling.
Ease of access: Online communication is a medium in which many people choose to communicate and by targeting residents via their preferred means, the likelihood of involvement is increased. Users can take part in an online consultation when and where they want – at home, on the move. Many chose to do so late at night. Because of its increased accessibility, online consultation has the power to reach new audiences – particularly the young and the time-poor. Local authorities welcome developers’ inclination to consult more widely; simultaneously this enables developers to unearth the support of the ‘silent majority’.
Dialogue: Online consultation allows for real-time dialogue and an exchange of ideas on a one-to-one, one-to-many and many-to-many basis.
Removing hierarchies: Online consultation has no regard for the limiting social stratas that we impose on ourselves. In a busy public meeting, for example, attendees may defer to a dominating character or group leader. Ultimately those members are not adequately represented, despite their presence. Online, and particularly behind the veil of a username, individuals are more likely to voice opinions without fear of repercussions, while personal details remain confidential but are accessible to the local authority as a confidential appendix to the consultation report.
Reaching ‘hard to reach’ groups: Many people – particularly commuters, families with young children, the elderly and disabled – are not easily able to attend consultation events. Online consultation provides an alternative, accessible means of engagement. Online consultation can be accessible in both its language and in the varied ways in which information is presented.
Promotion: Social media, blogs and the local media online can assist in communicating messages quickly.
Moderation: Both websites and social media can be monitored effectively. The way in which a consultation is to be moderated should be determined at the start and ideally communicated via a user guide to ensure consistency. For example, it should be decided in advance whether user generated content is to be vetted before appearing and if so, on what basis comment might be withdrawn.
Analysis: Online communication can be very effectively analysed: comprising day-by-day website usage; average session times and bounce rates; analysis of the most popular pages; demographic information in relation to location, gender, age and interest; analysis of how people are reaching the website; results per poll / forum / survey / blog comment; maps to depict the location of respondents. Likewise qualitative analysis which combines a technical and human approach can be more sophisticated than offline analysis.
Feedback: A consultation website, email and social media provide ideal means for communicating feedback.
Taking this into account, it is not surprising that most consultations are now both online and offline. This is also true of individual tactics: it would be inadvisable to host an offline event such as a public exhibition without announcing it online; likewise, a website or social media campaign would benefit from being promoted both online and offline.
But although it does much to benefit consultation, online consultation is not a panacea: this new selection of tactics presents a new set of risks. The fast dissemination of information online, although beneficial in many circumstances, can also be a disadvantage. In cyberspace information can fragment quickly and become used by pressure groups to reinforce their interests and prejudices.
Furthermore online consultation, particularly social media, can be seen as superficial and lacking the emotional power and empathy that face-to-face communication can bring. Online profiles can mask identities and if measures are not put in place, it can become impossible to monitor the geographical origin of comments. Standardised response mechanisms give online consultations a bad reputation, and should be avoided in most circumstances. And despite the increase in online communication, a digital divide still exists, particularly affecting BME and older groups.
Online consultation – addressing the risks
Online consultation is relatively new and a fear of the unknown persists despite many success stories. Common concerns are that the consultation will be hijacked by trolls, that the website will be open to corruption, and that registration will be off-putting.
Online, a ‘troll’ is an entity which takes part in discussions purely to disturb other users. Potentially a troll can anger people, disrupt the flow of debate/discussion and use abusive language. Anyone who has run a consultation will know that this behaviour operates both on and offline. Online, there can be effective means of dealing with trolls. It is extremely important to identify this either as anti-social behaviour or merely an impassioned and negative response to the consultation: unpalatable though it may be, the latter should not be dismissed, as everyone is entitled to put forward their views on the subject being discussed. However, activities which are clearly anti-social and thwart the objectives of the consultation should be stopped. Software can be used to identify bad language and ‘spam’ and is advised, in conjunction with monitoring. Where necessary, posts can be removed with immediate effect, IP addresses banned and usernames invalidated. Should a local issue have potential to escalate into a national issue and draw response from across the globe, mechanisms can be implemented to allow only those within a specific postcode area to register to take part in online forums, and the electoral register can be used to check the veracity of identities given. In online consultation, preventative action can be almost too easy: it should only be used when absolutely necessary.
With hacking, phishing and spam affecting our daily lives, it is unsurprising that issues of cyber security concern those running consultations. Certainly an unprotected website can leave itself open to abuse and if user details are being collated via an online database the legal and reputational impact can be considerable. However, all websites can benefit from EV (Extended Validation) SSL (Secure Sockets Layer) certificates which ensure that all communications – including user names and passwords – between the browser and the website are encrypted and can only be accessed by the website owner.
Registration can be extremely beneficial in restricting consultation responses to a specific locality and understanding more about those taking part. However, those running the consultation should also consider the downsides of registration: potential users may be reluctant to pass on email addresses, passwords and other personal data, and may be put off by the amount of time (perceived or otherwise) that registration demands. Consultation websites should seek to make the process simple and reassuring, explaining the need for registration, referring as appropriate to the security measures in place and making the process as smooth and simple as possible. Typically a consultation website will require a name, postcode, username and password. Any other information, such as a full postal address or demographic data (age, employment or marital status) should be given voluntarily and it is advisable to request this data at a later stage, allowing the user to have built up trust and respect for the consultation and appreciate the benefits in supplying such data.
Understandably tactics as new and as powerful as online consultation can raise concerns. But by far the greatest risk in online consultation is not connected to the consultation website itself but the absence of it: failure to provide a platform by which local residents can discuss a proposed development online can result in the developer being unaware of other online discussions, which can then gather momentum and perhaps only come to light when it is too late to address concerns or misapprehensions.
With the potential pitfalls effectively addressed, online consultation can lead to more efficient and more effective consultation. This will continue to benefit research and evaluation and will also assist and complement participatory planning. I have no doubt that over the next ten years and beyond, consultation will continue be transformed by technological change.
How can be online consultation be made to work effectively?
Plan
Have a content plan in place – but be flexible.
Watch and listen – determine what works best for the particular consultation, when to post and lengths of posts. Google Analytics is a very helpful tool for understanding user patterns.
Research
Use stakeholder research and analysis to gain an understanding of the likely take-up.
Use a consultation mandate to establish aims and objectives and guidance on usage
Ensure that a consultation mandate (a statement on behalf of the developer on how the consultation is to be run) is displayed prominently – or that its content is expressed clearly.
Put rules for engagement in place via a user guide.
Communicate the purpose and process of the consultation. Make the timeline clear and adhere to it where possible; where this is not possible, ensure that the audience is fully informed.
Be realistic about how quickly you can respond to questions raised online and communicate your commitment to respond at the start of the consultation.
Make access a priority
Avoid making the online consultation too complicated: always consider the less digitally aware when drafting web content and functionality.
Consider the benefits of making all (or specific) polls and forums available only to local residents by requiring that they register using a postal address.
Bear in mind that registration can deter involvement. If using a registration process, ensure that this is quick and simple, and doesn’t demand so much information as to be off-putting.
Let people register and get started quickly. Only those with a strong objection to a proposal will persist with an onerous registration process.
Select tactics with careful consideration
Use a variety of online tactics, providing the tactics are in line with the consultation objectives and deliver meaningful results.
Aim to use a combination of qualitative and quantitative tactics online.
Ensure that all tactics, where possible, include an opportunity to respond.
Create compelling and useful content
Create an enticing home page. Consider the use of video as an icebreaker.
Bear mind that people have shorter attention spans online. Write content specifically for the website: do not be tempted to simply install the content of a document or leaflet online.
Ensure that text is crisp and clear at all times.
Break substantial information into manageable chunks.
Ensure that information is presented in a variety of different ways.
Provide enough information to enable people to make an informed response.
Create content that is suitably compelling for people to engage with and share.
Use images, illustrations, maps, videos and slideshows to bring the content to life.
Link surveys and forums to background information to ensure that those responding are adequately informed.
Provide ample visual material. Mapping can enable residents to zoom in on an areas in detail and add text, video and comment.
Consider the use of slider bars. This is a visual and effective means of determining relative levels. It works well in budget setting but could also be an engaging and useful tool for community input in landscape design or other decisions.
Blog: a powerful way to provide regular updates and invite responses
Post regularly and on behalf of various members of the development team but determine how comment on blogs will be fed into the analysis prior to permitting comment.
Consider allowing members of the community, such as representatives of a stakeholder engagement group, to blog.
Ensure that those who blog on behalf of the development team understand the key messages and the scope of the consultation.
Use information to demonstrate transparency
Document libraries can be used to hold complex planning documents such as relevant local planning policies, or at the end of the process, the documents which make up the planning application.
Use hyperlinks to enable consultees to access extensive information if they choose to do so (ensuring that the hyperlink opens a new window rather than taking the residents’ attention away from the consultation website).
Involve via online forums
Use online forums to invite comment and discussion on a range of issues.
Prior to launching an online consultation, determine to what extent the development team will interact and if so, whether to do so in a corporate character or an individual’s name.
If taking part in online forums aim to facilitate, but avoid arguing at all costs.
Use issues ranking to gain statistical results
Put in place a mechanism whereby residents can select a preferred option from a list of choices, and second and subsequent lists are selected by routing software in relation to the initial choice.
Use social media with care
Don’t be tempted to use social media just because it’s there: consider its function and whether it can meet the aims and objectives of your consultation. Facebook, for example, was designed as a means to communicate with friends, share photographs and videos and to arrange social activities. It has the means of addressing some consultation objectives, but due to the inability to gain user data and therefore meaningful analysis, Facebook’s role as a consultation tactic is limited.
Likewise, Twitter is a useful means of promoting a consultation but its 140 character limit restricts meaningful dialogue.
Bear in mind that many people choose not to use social media, and those that do may not choose to use it to comment on a development proposal. It should not be the sole means of online consultation.
If you set up a social media profile, keep it active: nothing communicates a reluctance to communicate more effectively than a dormant Twitter feed or Facebook page with unread Friend requests and posts. Maintaining a social media presence is a time consuming process but can be helped by scheduling posts and setting up automatic monitoring, with results directed to a designated email account.
Promoting an online consultation
Bear in mind that consultations are never solely online or offline: successful consultations use online to promote offline tactics, and offline to promote online tactics.
Use Search Engine Optimisation (SEO) to ensure that the website can be found easily.
Consider a range of other tactics such as links on other relevant websites, local press and broadcast media, blogs, social media, links on email sign-offs, signage, posters and newsletters.
Be as responsive as is feasible
Provide a means for respondents to contact a person if necessary – ideally both by email and phone.
Determine in advance whether you’ll interact on public forums – and if so, ensure that the role is one of facilitation, not refereeing.
Ensure that all those posting / responding on behalf of the consultation do so with the same understanding.
Respond promptly.
Keep registered users updated – via email, RSS, SMS or social media.
Remember that communication online is immediate and 24/7
Commit to regular posting. Social media posts can be scheduled via a range of dashboard applications such as TweetDeck and Hootsuite.
Keep the website fresh and up to date.
Check links regularly.
Update the website regularly.
Ensure consistency throughout the consultation
Ensure that the online content is in keeping with offline content – this is particularly appropriate if the two parts of the project are being run by different teams.
Ensure that messages are consistent throughout the website and the wider consultation.
Monitor constantly
Set up monitoring from Day One. This may be both automatic (for bad language / spam) but should not be exclusively so.
If you have to remove a post, let its author know and give them an opportunity to replace it.
Avoid vetting comments as this can lead users to question the transparency of the consultation more generally.
Provide links to offline consultation, allowing respondents to take part both online and offline.
Promote
Encourage sharing on social networks to help spread the message.
Focus on results
Avoid the temptation to ask open questions the results of which may be difficult to monitor and analyse.
Ensure that the consultation website provides a means of quickly extracting information for reporting and evaluation.
Leave a Comment The law surrounding statutory consultation is extensive.
And yet when developers consult on planning applications, there is a stark absence of official guidance, regulation and case law. Why, in a discipline led by professionals – chartered surveyors, planning consultants and lawyers – is the approach to consultation so lacking in professional rigour? Because in most cases, there is no statutory requirement for consultation and therefore no legal framework.
True, there is law relating to consultation on Local Plans, Nationally Significant Infrastructure Projects (NSIPS), Neighbourhood Planning and on that carried out by local authorities prior to determining planning consent. But for many new schemes there is no duty to consult under English law.
The situation might have been very different. The 2010 Localism Bill introduced a requirement for developers to consult communities before submitting planning applications. But this was omitted from the resulting Localism Act except in the case of wind turbines. Developer engagement is instead determined by the relevant planning authority, and local authorities’ inclination towards consultation varies considerably.
The advantages of developer consultation are numerous. Consultation can deliver a real insight into a local area, create enduring beneficial relationships and enable an early understanding of any issues or misunderstandings which may stand in the way of planning success, thus save time and money.
I recently attended tCI’s The Law of Consultation conference. As a consultation consultant working with developers and planners, I was immediately struck by the extent to which regulations and case law impacts on so many consultations, but not on mine. Rather than feel relieved to be free of such restraints, I saw how guidelines and past cases drive up standards in consultation in a way which is lacking in my industry.
There are some excellent examples of best practice consultation in planning, but a lack of consistency: enlightened developers devise consultations which are open, transparent, accessible and engaging, but too much engagement is minimal. While enough to qualify for planning consent, ‘consultations’ are invariably rife with leading questions, lacking in information and used solely to justify a foregone decision. Sadly it is this which is reported in the local media, tarnishing the reputation of both planning and consultation.
The Government has recently consulted on changes to the National Planning Policy Framework. The Consultation Institute, of which I am an Associate, responding requesting a tightening up of legislation surrounding planning and development. I see this as necessary to reduce the current confusion over obligations, to put in place some consistency and in doing so, to drive up standards in consultation.
Prior to any legislative changes taking place, for anyone responsible for community engagement on behalf of developers, I would thoroughly recommend The Consultation Institute’s Consultation Law training: far from being irrelevant it is an excellent means of gaining understanding best practice across a variety of sectors which can have enormous benefit on pre-planning consultations.
First published on the Consultation Institute website March 2019Penny’s bookPublic Consultation and Community Involvement in Planning: a twenty-first century guideis published by Routledge. It is available online through Routledge, Amazonand other bookshops.
Consultation can deliver a real insight into a local area, create enduring beneficial relationships and of course provide the information necessary for a comprehensive Statement of Community Involvement (SCI) and ultimately achieve planning success.
Yet frequently developers view consultation as a risk – more often than not because of concern that vocal locals may ambush events or insist on unviable changes.
But there is good news for those who view consultation as acrimonious shouting matches in draughty village halls: public consultation has moved on. This article describes ten ways in which today’s consultations can engage effectively while minimising risk.
Understand the audience and its motivations
The phrase ‘know thy enemy’ is inappropriate in the spirt of cooperative consultation but it certainly encapsulates the benefits of initial research. This includes understanding the number of residents to be targeted, the diversity within the community, its influencers, informal groups and patterns of interest, and opportunities to reach certain sections of the community – the ‘hard to reach’ but also importantly the ‘silent majority’.
Information about stakeholders and their contact details, relevant influences and opinions can be collated in a simple database or on stakeholder engagement software. This enables individuals to be pin-pointed geographically, can reveal which sections of society are likely to respond to the planning application and how, and can enable excellent analysis. Databases should be continually maintained and expanded but used only for the purpose of the consultation and data protection rules must be adhered to – including GDPR legislation which takes effect in May 2018.
The next stage is to consider the specific issues likely to influence the consultation. Knowledge of wider concerns (whether real and perceived), such as housing need and pressure on existing infrastructure, can provide a context for consultation responses and, importantly, enables the development team to address any misapprehensions. An issues database can set out the issues alongside an agreed response. As issues change during the course of a project and themes emerge or develop, the document should be updated.
Usually such documents are not public but are shared within the development team to ensure that responses to difficult subjects are communicated with consistency. That said, an issues document (or elements of it) is frequently the basis for Frequently Asked Questions which may be displayed on the consultation website to show that the developer is aware of residents’ concerns.
Communicate the purpose of the consultation – the consultation mandate
Many years of experience have taught me that the most effective way of keep a consultation on track and mitigating any criticism is to begin with a consultation mandate. Essentially this is promise to local residents which sets out the consultation purpose and objectives, the subject for discussion, the proposed programme and the application of the results.
The consultation mandate is the best opportunity to put in place rules which then govern the consultation. For example, if it specifically disallows irrelevant comment or bad language from the consultation website discussion boards, the consultation mandate is justification for removing such comment.
At the end of the process, the consultation mandate provides the ideal opportunity to evaluate the success of the consultation, demonstrating that it set out what it intended to do.
Ask the right questions
Within reason, well-drafted questions have considerable potential to reduce negativity. In the case of an outline planning application, the consultation will focus on the content of the masterplan, rather than principle of development. The questions can then reiterate this – for example, ‘The Local Plan has identified a need for 30,000 new homes in the area to the period to 2035. This scheme provides for 4,000 homes. Given that a significant amount of new development is already agreed, are you in favour of our approach of providing family homes and apartments in five connected village settings?’. This approach avoids discussion on the housing figures within the Local Plan and concentrates the discussion on the features of the masterplan.
Don’t leave a vacuum for gossip to spread
Many developers are wary of consultation stirring up negative sentiment and providing an impetus for opposition groups. But a reluctant consultation is a risk in itself.
This is particularly seen online, where failure to provide a means by which local residents can comment on a proposed development can result in those discussions taking place elsewhere online. In these situations, the developer may be unaware of escalating issues, which may only come to light when it is too late to address concerns or misapprehensions.
Mitigate risk online
Consequently, consultation websites are increasingly common but online consultation is relatively new and its take-up is often limited by a fear of the unknown. Common concerns are that a consultation will be hijacked by trolls, that a website will be open to corruption, and that registration will be off-putting. While each of these are genuine concerns, they need not stand in the way of a good online consultation, which can have numerous benefits – engaging tactics, increased accessibility and thorough reporting to name but a few.
Online, a ‘troll’ is an entity which takes part in discussions purely to annoy and disturb other users. Anyone who has run a consultation will know that this behaviour can operate both on and offline. Online, there can be effective means of dealing with trolls. Disruptive behaviour can be stopped on the basis of the consultation mandate, as described earlier. Additionally, rules and regulations in relation to harassment, bullying and bad language can be contained within a website user guide. Software can be used to identify bad language and ‘spam’. Where necessary, posts can be removed with immediate effect, IP addresses banned and usernames invalidated.
Consultation websites should be run with utmost security, not only to prevent hacking, phishing and spam but also because where user details are being collated, the legal and reputational impact of this falling into the wrong hands can be considerable. All websites can benefit from EV (Extended Validation) SSL (Secure Sockets Layer) certificates. Websites with this functionality display a padlock icon and https (Hyper Text Transfer Protocol Secure), rather than simply http (Hyper Text Transfer Protocol) in the URL. This means that all communications – including user names and passwords – between the browser and the website are encrypted and only accessible by the website owner.
Registration can be extremely beneficial to a development team – for example, in restricting consultation responses to a specific locality and understanding more about those taking part. However, the need to register can be a deterrent. Potential users may be reluctant to pass on email addresses, passwords and other personal data, and may be put off by the amount of time (perceived or otherwise) that registration demands. Consultation websites should seek to make the process simple and reassuring, explaining the need for registration, referring to the security measures in place and making the process as smooth and simple as possible.
Media management
There is an assumption that the media is naturally anti-development, that a local newspaper will always champion the voice of the resident over that of a corporate entity, and that bad news is more likely to make the headlines than good news. Admittedly this is sometimes true, but what better justification is needed for developers to engage with journalists?
Few developers communicate with the local media in the early stages of consultation, entering into dialogue only (and often reluctantly) when a negative issue has been brought to the attention of the media. Frequently a negative, unbalanced and perhaps inaccurate story will have been published by this stage, causing substantial damage both to the consultation and the reputation of its partners.
As with local residents, positive relationships with the media are based on provision of information and a positive, open and transparent approach.
My recommended approach is to contact the local newspaper at the early stages of a consultation: use the consultation mandate to explain the process and remit of the consultation, ensure that the local media is fully furnished with facts and positive messages and has contact details in the case of future questions. The result is typically a positive story in the first instance, and a more balanced story should local residents approach the newspaper with concerns about the consultation or development proposals.
Tackle issues head-on
Perhaps one of the greatest fears of those running a public consultation is negativity voiced by local interest groups, national activists and so-called NIMBYs.
Earlier I mentioned the importance of researching issues at an early stage and creating an issues database. Technically there is little need to respond to points made until the end of the process; however, where contentious issues are raised and misapprehensions spread, it is often beneficial to respond to emerging issues in a public forum and at the very least will put misapprehensions into context for the purpose of the SCI. An issues database, whether publicly accessible or kept for reference purposes, can include figures relating to statistics (increased traffic figures in the case of a new road, housing allocations in the case of a detail development), and financial data (employment opportunities and the value of new scheme in monetary terms).
It can be hard to change feelings with facts, but facts can certainly help.
Unearth positive responses
It is commonly known that those living closest to a development are most likely to object to it: perhaps because of the impact on their view, the pressure on local infrastructure, or merely the disruption of the construction process. Consequently there is considerable benefit in extending the geographical reach of a consultation in such a way that it includes those who will enjoy the benefits of the proposed scheme but aren’t swayed by these more subjective factors. Online consultation provides an ideal means for doing this: specific interest groups in the region might be contacted in relation to a new facility, and the users of large scale organisations targeted through social media.
Manage expectations
The promise of a substantial new amenity and a commitment by its developers to consult widely can raise expectations among local residents. But the higher the expectations, the greater the criticism – both of the proposals and of the process – if they are not met.
Pre-consultation can enable a developer to discuss the remit and nature of the consultation with the local authority, special interest groups and in some cases, residents, at an early stage. Where a gulf exists between expectations and reality, this should become apparent and can be addressed. Often the solution need not be to offer more by way of consultation, but to consult in a way which is more suitable to the specific community.
Communicate results
A consultation will disappoint if the consultation itself is at fault (it has failed to engage) or if its results are unwelcome (either failing to respect resident sentiment or perceived to be inaccurate). Either way, disappointment can fuel negativity – sometimes online, sometimes in the local media – and in the case of a developer’s planning application, may coincide with the point at which the planning application is being consulted upon by the local authority or considered at planning committee. At this stage it is generally too late for developers to change the consultation process or adapt proposals, and faced with possible criticism at a planning committee, the options are to withdraw and amend the application or risk it being refused.
Evaluation is helpful in justifying the outcome: where a specific consultation framework has been put in place using pre-consultation dialogue and research, agreed with the local authority planning department and run accordingly, local authorities will understand that the consultation has met its objectives, despite opposing voices. Negative comment can be viewed in relation to the consultation remit, misapprehensions corrected and concerns addressed. Often overlooked on the basis that the consultation is complete, a diligent response as the final stage of the consultation process benefits both the SCI and ongoing communication with local residents during the construction phase.
There is no prescription for a risk-free consultation, because no such thing exists. But a consultation which is open, transparent, accessible and engaging will encourage comment. In the eyes of the local planning authority, a good consultation is not one which is free of negative comment, but one which produces informed responses capable of shaping future plans and are accordingly.
Invariably a strategic approach to a consultation, starting with a consultation mandate, is the best way to mitigate risk. And a consultation which uses this through approach avoids the risk of failing to produce an adequate SCI.
The internet provides not only a new platform on which to communicate: it changes the manner in which we communicate. The world of online communication is, by and large, very democratic and non-hierarchical. Every user has the potential to broadcast a message to millions worldwide at the touch of a button and consequently the concept of ‘citizen journalism’ is growing by the day. That message will then appear unaltered and without confusion of an external influence. In principle if not in practice, a level playing field has been created and large organisations which were once able to use their position to influence are now exposed to previously unencountered levels of challenge and opposition online. Consumers now have greater expectations from organisations and the power to ask for information publicly. Through the internet we have a greater opportunity to be informed and also a greater capacity to seek knowledge. But where the lack of an organisational filter removes the need for checks to be made, misinformation can occur.
With the advent of Web 2.0 in 2004, the extent to which people could collaborate, comment and share information increased, resulting in the internet ceasing to be only a vehicle through which information could be sought to an opportunity to both broadcast information and enter into dialogue on a number of levels. The speed by which information now travels would be inconceivable to someone living in the first half of the twentieth century – through websites, blogs, social media, apps and email, information can be both sought and imparted within seconds. Not only does the initial message occur immediately, but a post, email or Tweet can be shared with similar speed, ‘snowballing’ and thus reaching millions. Many websites will now enable this to occur automatically – composing a Tweet or a link to Facebook the moment a purchase has been made or a poll completed – crucially, with little or no effort on the part of the author / publisher. In fact, the curating and sharing of a piece of information can occur devoid of human interaction: the algorithms that power Facebook and Google are responsible for much of the content that we consume.
The American University Center for Social Media[i] identified internet usage as falling into five categories: choice, conversation, curation, creation, collaboration. In a planning context, these behaviours might be described as follows:
Choice: finding information on Local Plan formation, policies and planning applications though search engines, recommendations (on or off line), news feeds and niche sites.
Conversation: entering into debates on discussion forums, blogs and microblogs, taking discussions into new forums by sharing links and mobilising action.
Curation: selecting and drawing together information on blogs to form powerful arguments, carefully targeted to specific groups; posting and reposting views and suggestions and sharing links.
Creation: posting brand new multimedia content, including text, images, audio and video rather than simply responding to information posted by a local authority, developer or government body.
Collaboration: creating groups of support or opposition for the purposes of campaigning both online and offline
As the capabilities of the internet, along with internet usage, grow, the opportunities for involvement within each of these categories will undoubtedly increase and individuals’ behaviour online is likely to become less passive and more powerful. Developers who opt not to have an online presence, or install a consultation website with no mechanism for dialogue, run the risk of their scheme being debated on closed blogs and Facebook groups and as such will be unaware of any mounting objection until it becomes too late to prevent it. The industry must accept the changing communications landscape and monitor sentiment and proactively encourage constructive consultation online.
Taken fromPublic Consultation and Community Involvement in Planning: a twenty-first century guideby Penny Norton, to be published by Routledge on 10 July 2017. Pleaseemail Pennyto receive notification of its publication.
[i] Clark, J and Aufderheide, P 2009 Public Media 2.0: Dynamic Engaged Publics Washington, DC : Center for Social Media.
The difficulties of involving ‘hard to reach’ groups is perhaps the most enduring issue in consultation. That said, the definition of those classified as hard to reach is changing.
Previously the elderly, disabled, black and minority ethnic (BME) and women were singled out as requiring additional outreach support. Today, older age groups and women may be among those most likely to respond to a consultation but issues still remain: whereas the 65-75 age groups is very likely to contribute to a consultation, the very elderly remain unrepresented; and whereas women are now much more likely to engage in consultations independently of their husbands than 50 years ago, parents of young children are considered hard to reach due to time pressures and the practical difficulties of attending evening events. Recent entrants to the list of hard to reach are those who work, particularly commuters.
And while accessibility for commuters has been very successfully addressed through online consultation, requiring people to use IT to respond to a consultation – perhaps to be more proactive in finding the information, to be expected to do so via online networks, to comprehend information on screen and type responses – has accessibility issues.
Local authorities consulting on strategic planning will have equalities agendas that they must comply with. Policies will recognise that different sections of the community, particularly minorities, have specific needs which should, as a democratic right, be recognised. Failure to take account of people’s differences could result (particularly in the case of public bodies) in claims of indirect discrimination.
For developers, particularly those in the private sector, there are considerable benefits in reaching out to specific groups. Discussions with the local authority at pre-consultation stages should include the ways in which the consultation may be made representative of the wider community.
It goes without saying that it requires a greater investment of time and other resources to work with those groups identified as hard to reach. Early dialogue should be used to gain a real understanding of a local community and ensure that issues can be identified prior to the consultation strategy being put in place .
It is important never to treat hard to reach groups as an undifferentiated mass: each of those groups identified above (and subsections within them) have very clear interests and needs. A consultation should have a clear understanding of those groups it needs to reach and invest time in understanding them. This might include knowing where specific groups congregate, their media consumption and which issues concern them. It is always very helpful to identify the leaders – both formal and informal – with a view to establishing initial contact through a representative. Local authorities are well placed to advise on specific groups, and in many cases can provide or make recommendations regarding translations, interpreters, and advise on physical accessibility. For long term consultations it is often prudent to employ or train a member of staff with responsibility for specific groups.
A consultor should consider whether processes are too restrictive. For example, some consultations will only accept responses made in writing or those made at a specific event. Again at the early stages, the various ways in which responses can be elicited should be considered – always ensuring consistency with the consultation’s objectives and the ability to analyse and evaluate responses, and to maintain consistency throughout the process. The consultation mandate should stipulate that the principles guiding the consultation will include those of openness and accessibility, and the consultation should reflect this commitment throughout.
The next blogs on the subject of hard to reach groups will address each of the specific groups in turn, providing some practical advice on the best way to reach them.
Penny Norton
Penny’s book Public Consultation and Community Involvement in Planning: a twenty-first century guide is published by Routledge in August 2017. Please email Penny to receive notification of its publication.
In some cases, the consultors’ voice is rarely heard in the discussions; in others clarifying the messages and stimulating the dialogue will be necessary to ensure an effective consultation.
Determining to what extent monitoring should become involvement depends upon the following:
Whether the consultation is successfully meeting the consultation objectives or whether intervention would ensure greater success – for example, is the community well represented, or does work need to be done to bring others into the consultation?
Whether dialogue is focused on the purpose of the consultation – is intervention required to bring the discussion back on track?
The accuracy of the discussions – if misapprehensions have arisen it is usually necessary to provide clarification.
Promises made to the consultees – if a consultation mandate is being used, did it stipulate that dialogue would be between residents, or between residents and the organisation running the consultation?
The consultation’s messages – are the messages receiving the necessary airtime, or does a particular message need to be brought to the fore?
Bias – would intervention by the consultor be seen as ‘leading’ the results of the consultation?
Symmetry and responsiveness – conversely, in not taking part in discussions, is the consultor failing to put across important information and to respond to points made?
Information gathering – could more be learnt by asking questions?
Every consultation is different and some will require more involvement on the development team’s part than others. The level of involvement therefore should be a decision unique to that consultation – but hopefully the ideas above should help in making that decision.
Penny Norton
Penny’s bookPublic Consultation and Community Involvement in Planning: a twenty-first century guideis published by Routledge in June 2017. Pleaseemail Pennyto receive notification of its publication.
It pays dividends for those running a consultation to have as clear as possible an understanding of the issues that will effect it before the consultation begins.
In communications theory, an issue is usually described as, ‘an unsettled subject ready for debate or discussion’. In a development consultation, this typically includes concerns about the site, the proposals, or the impact of development more generally.
Identifying issues enables the development team to fully understand the context of the consultation responses and, importantly, to address any misapprehensions. It is inevitable that development consultations will involve emotive and potentially divisive issues. Development on green fields, social housing and increased pressure on existing resources (roads, healthcare, and education) frequently give rise to debate. Their potential impact, whether realistic or simply perceived, should not be overlooked as it is necessary for the development team to respond to these issues when required, without delay, contradiction or confusion.
At the start of the consultation I would suggest putting in place an issues or Frequently Asked Questions document for use within the development team. This sets out each of the issues likely to arise alongside the agreed response. The document must be flexible, as issues will change during the course of the project and new themes will develop as new topics are discussed. Others may fall away as the community becomes reassured of the developer’s approach and misapprehensions are resolved.
Consider the merits of making the document publicly available. Initially it might seem idiotic to air contentious issues that no-one has brought up. Yet. But what if people are thinking about those issues, discussing them on the street and on closed Facebook pages, and drawing the wrong conclusions in doing so? An issues database or FAQ is a great way to stop misapprehensions from developing, and it also shows the developer to be truly committed to transparency in consultation – something which will reap benefits in the future.
Penny Norton
Penny’s bookPublic Consultation and Community Involvement in Planning: a twenty-first century guideis published by Routledge in June 2017. Pleaseemail Pennyto receive notification of its publication.
Construction can be a difficult time for developers and the neighbourhoods in which they are working. As my previous blog has shown, there is a lot that can be done to mitigate the impacts of construction. But a more proactive approach can make the difference between good and bad relations with a local community.
Education and employment
Development teams frequently use education as a means of reaching stakeholders both during the planning stages and beyond. Working with schools reaches not just children, but their families too, often within a very specific geographic area. Similarly, developers and construction companies have skills which can be of use to the wider community and this too can help develop positive relationships with the site’s neighbours.
Through these initiatives, the development team is able to better understand its local community and in doing so, address local issues, grow local businesses and provide skills training to help regenerate; develop community cohesion; continue to consult, where appropriate, on the details of the scheme; and create interest in the development – attracting workers, shoppers and residents.
Environmental initiatives
In recognition that a new development may have, albeit only in the eyes of a few, a negative impact on the fabric of a neighbourhood, developers frequently make environmental improvements to a neighbourhood. Typically this involves developing a nature reserve, creating the means by which endangered species can be protected (bat boxes are common) or making a contribution to a local park or woodland
The arts
Using the arts as a form of community engagement enables the community to work collaboratively on a process which is creative, fun and can be directly relevant to the development itself; and in can provide a positive experience in the process and result in a product which endures and provides a long term reminder of the collaboration. The involvement of a community arts worker or professional artist can provide a helpful bridge between the developer and the community, and the process can create a sense of ownership in the new development.
Arts work can take various forms, encompassing visual and performance arts; permanent or temporary; a product by or for the community. The resulting piece is often inspired by the architecture of the new development, or may link to the site’s previous use.
Sponsorship, support and sponsorship-in-kind
The variety of skills that make up the construction and development team have a great deal to offer the local community. Sometimes a seemingly simple activity such as providing the use of the landscaping team to overhaul a pocket park, or members of the construction team to rebuild a brick wall at a local school will present an excellent opportunity to forge links with the local community. Sometimes this might involve skills sharing – teaching jobless young people the skills of gardening or brick-laying, or offering talks about careers in construction at a further education college.
Sponsorship too is popular. A developer or construction company will often provide a new kit for a local sports team which provides both an opportunity to meet local residents in a non-adversarial context and to gain brand recognition at football matches and in the local media.
Initiatives such as these can have multiple benefits – not only in mitigating the impact of construction but to reputation, corporate social responsibility and the long term success of the new development.
Penny Norton
Penny’s bookPublic Consultation and Community Involvement in Planning: a twenty-first century guideis published by Routledge in June 2017. Pleaseemail Pennyto receive notification of its publication.
During the early stages of a consultation, when a strategy is put in place to determine the direction of the project, it will be necessary to consider whether you will allow people to respond anonymously.
While anonymity has been shown to enable people to put forward their viewpoint without fear of repercussion, it could be argued that anonymous results cannot be verified at the evaluation stage and therefore carry little weight.
Consider the following factors when making the decision:
Arguments in favour
Respondents are more likely to express their views without fear of repercussions
Breaks down power relations
Frees up individual expression
Removes bias
The argument can be focused on the content of the discussion without prejudice
Undermines collaboration
Arguments against
A consultation report carries more value if comments can be attributed
An individual should be prepared to ‘own’ his / her comments
People are more likely to be dishonest when unidentifiable, or to use a forum to praise themselves
Individuals may be able to put forward their views on numerous occasions by using different log-ins
Anonymous contributions lack demographic data, which can be very valuable in a consultation
De-personalises comment
Penny Norton
Penny’s bookPublic Consultation and Community Involvement in Planning: a twenty-first century guideis published by Routledge in June 2017. Pleaseemail Pennyto receive notification of its publication.
It goes without saying that local residents will be more positively engaged with a development team and less critical of it if their locality is kept clean and safe, and that they are provided with timely and adequate information should their daily lives be disrupted.
The following tactics are all regarded as good practice in overseeing community relations:
The appointment of a community liaison officer is an excellent starting point as this ensures a single point of contact for local residents, a co-ordinated and consistent approach. In some cases, this role may be taken on by a Construction Impacts Group or development forum.
Newsletters, emails, a community relations website and social media, telephone helplines and exhibitions in local community centres have found to be useful in imparting information.
Face-to-face and small community group meetings enable the development / construction team to speak directly with those individuals affected and respond to their concerns.
Community liaison panels are a more formal means by which the development team can understand residents’ concerns, but are smaller and more manageable than public meetings.
A simple means of sharing news about the development is to provide plastic windows in hoardings, enabling local residents to view progress on site. This can also be provided through the use of a webcam or series of photographs, hosted on a website or social media page.
Other engaging ideas used to encourage local residents to engage with the development team include the creation of community reporters (local people given the opportunity to interview the development team and report back to the community in the form of a newspaper or blog) and a regular drop-in café to encourage direct communication between the construction team and community.
The local media can be a useful means of providing updates to the wider community and also establishing a positive relationship with a local journalist which can be useful in the case of complaints.
The development team also has the opportunity to involve the community in events, such as ‘topping out’ a significant building, opening a play area or aspect of infrastructure.
Community relations is a vital component of development and one which should flow naturally from a well-run planning consultation.
Successful community relations requires a strategic and principled approach, early engagement and a realistic and appropriate set of tactics. Whether you’re communicating directly with residents to mitigate future problems or putting in place positive programmes of engagement, there is a wide variety of tactics available.
Penny Norton
Penny’s bookPublic Consultation and Community Involvement in Planning: a twenty-first century guideis published by Routledge in June 2017. Pleaseemail Pennyto receive notification of its publication.
What are the ‘right’ questions to ask in a consultation on a development proposal? Unsurprisingly, there is no ‘right’ answer! Consultation can range from an issues-based exercise which encourages a wide range of ideas from its audience, to a referendum which invites residents to vote ‘yes’ or ‘no’ to a single idea. Ideally a consultation will include both open and closed questions.
Depending on the nature of the consultation, fully open questions such as ‘What do you think the development should comprise?’ can give rise to unrealistic answers or angry rants. It is often more helpful, both for the individual and the exercise, to provide guidance which focuses the mind and in doing so generates more meaningful responses. Issues-based consultations sometimes use the ‘dilemma’ approach: one that puts the consultee in the position of the consultor and in doing so helps them to make a more informed choice. For example, rather than asking the question ‘What do you want to see on this land?’ the dilemma approach would state, ‘We are required to provide between 800-1,000 homes and three commercial units on this site. Where do you feel the commercial units could be situated? What sized homes are most needed in the neighbourhood? Do you agree that the 30% housing association homes should be distributed evenly throughout the development?’ the alternative approach – seeing the proposal from local residents’ point of view – can also help address underlying negativity. For example, a telecoms company invariably faced with the comment, ‘I don’t want that mobile phone mast obscuring my view’, may ask questions relating to need at an early stage, starting with the question ‘Is your mobile phone coverage satisfactory?’
A decision must be taken as to whether to request demographic data. Most consultations will benefit from a detailed understanding of their respondents. In a site-specific development it is extremely useful to understand where people live and take this into account in relation to their response. Information relating to age, gender and employment status can also benefit analysis, but can be off putting. Rarely is it worth asking for demographic information if it deters a significant number of potential respondents. A tried and tested technique is to seek this information at the end of the process, rather than early on. It is also advised to make the provision of personal information voluntary, while both explaining its benefits reassuring respondents that the information will remain confidential and not used for any other purpose. The Information Commissioner’s Office provides useful information about handling personal data and anyone running a consultation should consider registering under the 1998 Data Protection Act.
While data which lacks user information lacks validity, an anonymous contribution is usually more valid than none. Online consultation demonstrates that anonymity can benefit a consultation in removing hierarchies. In an online consultation conducted by ConsultOnline 54% of those taking part in the consultation chose a username which bore no resemblance to their actual name, yet names, addresses and postcodes were supplied for the registration process. The lack of these comments would have been detrimental to the consultation, and while respondents were reassured that their personal details would not be made public, the development team had access to the demographic data necessary to create an excellent consultation report.
Ideally, a consultation should include a mixture of qualitative and quantitative tactics which, in turn, produce both qualitative and quantitative data. Questions should be closely aimed to the objectives of the consultation and most importantly, questions should only be asked if their responses can impact on the proposals.
Penny Norton
Penny’s bookPublic Consultation and Community Involvement in Planning: a twenty-first century guideis published by Routledge in June 2017. Pleaseemail Pennyto receive notification of its publication.
Have you ever responded to a development consultation where there is a clear consultation mandate in place? As a local resident, have you been presented with a document which sets out who the consultation is for, what it’s about, what it intends to achieve, how the results will be used and how you’ll be informed of the result?
Many of us probably haven’t been on the receiving end of a consultation which is so clear, so open and honest and so committed to the local residents involved. This is a shame, as there’s no reason why a developer shouldn’t put this in place, as it hugely benefits ongoing community relations as I’ve found.
A consultation mandate is simply a distillation of the consultation strategy for use by local residents. As the document will be read by a wide variety of people in a wide variety of circumstances, it is imperative that it is clear and concise, using plain language and a simple, accessible form.
Typically, a consultation mandate will include the following information:
The organisation running the consultation
The target audience
The aims and objectives of the consultation
The subject for discussion
Potential impact of consultation
The organisation initiating the change post-consultation
Timings
Try it out! Providing you state that the document is flexible and publish any updates on the consultation website, there’s nothing to lose.
Penny Norton
Penny’s bookPublic Consultation and Community Involvement in Planning: a twenty-first century guideis published by Routledge in June 2017. Pleaseemail Pennyto receive notification of its publication.
