East Devon Statement of Community Involvement (SCI) >>> a critique

The District Council have just issued a consultation document on ... how to deal with 'consultation' on planning matters:

Dear Sir or Madam

East Devon Statement of Community Involvement (SCI)

As you are on our database representing an organisation I am writing to advise that the Council is currently consulting on the new Statement of Community Involvement (SCI). This is the document which sets out how, where and when we will consult on planning matters such as Policy documents, planning applications and Neighbourhood Plans.

The SCI is available for comment  from 3rd July to 15th August 2018. All comments will be considered by the Council and will inform subsequent versions of the document.

Any comments should be marked ‘SCI’ and emailed to planningpolicy@eastdevon.gov.uk or posted to Planning Policy Team, East Devon District Council, Knowle, Sidmouth, EX10 8HL

Phone: 01395 571533

Here is the document:
East Devon District Council Statement of Community Involvement

From an initial overview, questions remain as to how much 'community involvement' there would actually be.

For example:

> Nobody wanted the employment land allocation at Sidford in the Local Plan, but it was included because of lobbying from the District's larger businesses and not because of any 'community involvment':
Futures Forum: Sidford business park >>> and the East Devon Business Forum revisited

> Not that the Environment Agency was listening either:
Futures Forum: Sidford business park > Fords planning application >>> 16/0669/MOUT >>> Environment Agency appears to contradict its own guidance on flooding and climate change >>> EA to reply to SVA

> Nobody asked for the District Council to move its HQ from Sidmouth: there was absolutely no 'community involvement' at the outset, but simply the pursuit of an obsession:
Futures Forum: Knowle relocation project 2008: “We’ll be seriously looking at the future of us staying in this building for numerous reasons.” OR: "Given current market values and the likely cost of relocation, it would be a close run thing as to whether a move was viable.”

> The Beach Management Plan for Sidmouth's East Beach has been beset from the start by the basic lack of 'community involvement':
Futures Forum: Beach Management Plan: and the consistency of the frustrations faced by the volunteer stakeholders >>> steering group to meet tomorrow, Thursday 10th May

> What to do about Port Royal never had anything to do with 'community involvement':
Futures Forum: Plans for Port Royal 2009: "We are desperate for someone to buy this site and to give us good money for it."

> Besides, the various bits of 'consultation' were abandoned anyway:
Futures Forum: Plans for Port Royal: "What were all these plans, meetings and consultations actually FOR?"
Futures Forum: Plans for Port Royal: "... following 18 months of consultation, communication and engagement with the local community to find out what they would like to see there."

The proposals set out in the latest document from the District Council do not look as if any of the above scenarios would not happen again in East Devon.

In fact, they do little to dispel the impression that 'consultation' is simply about ticking boxes:

Many government consultations are more about meeting legal requirements than listening : Democratic Audit UK
Tick-box “consultations” | East Devon Watch

This is all part of a greater political malaise:
Consultation by Parliament should be more than asking people for their views then ignoring them | East Devon Watch
“Alienated voters ‘don’t feel Brexit will help them retake control’ over decision making” | East Devon Watch

We need to get real about this:
Making Consultation Meaningful
Yes, we can make consultation “meaningful” and here’s how | National Newswatch

Which means going way beyond the passivity of 'consultation':
Futures Forum: "Consultation is not enough: that sometimes those affected by decisions improve the outcome not just by being heard, but by participating."

With the Neighbourhood Planning process being a good example of what can be done:
Consultations – Sid Valley Neighbourhood Plan
Sid Valley residents asked to take part in ‘the most significant’ consultation’ in the area | Latest Sidmouth and Ottery News - Sidmouth Herald

To finish with a proposal:

Tackling the ‘black hole’ of consultation

March 23, 2018

The Case for Public Consultation Hearings

In its latest Briefing Paper, the Institute argues the case for Public Consultation Hearings. In the recommended format, organisations undertaking a consultation will provide the opportunity for selected consultees to appear before decision-makers and give their evidence and their viewpoint – a little like Parliamentary Select Committees.

It is not a new idea, but there are important reasons why the time is right to consider these forms of dialogue:

> People are heartily fed up with perfunctory, tick-in-the box forms of dialogue, especially simplistic online surveys with questions like ‘Do you agree with us that we should revise the regulations …. Blah blah.? ‘ Serious stakeholders want a better level of debate that considers issues properly. Public hearings can help. 

> We have to tackle what can be described on the week of Stephen Hawkins’ death) as the consultation ‘black hole’ It is where respondents make a submission or reply to a consultation but have no idea what happens to their views. Does anyone read them? Are they considered? If so, by whom. It is as if responses disappear down a black home never to reappear. Public hearings are one way to demonstrate that consultors listen! 

> All the emphasis is now on digital dialogues, and they have many fine features that encourage participation by large numbers who might not have responded using traditional methods. Public hearings can be a welcome antidote to the de-personalisation of electronic media – where real people can be seen to sit down and discuss evidence. Video-streaming can make this visible and transparent to far wider audiences, and be living proof that consultation is really taking place.

The Briefing Paper looks at the role of evidence in public debate, and the need for participants in consultations to evidence their claims and assertions. It then presents the arguments in favour of public hearings, and explores whether they might work in the context of public consultations. For existing public engagement practitioners, the most valuable section may well be on the practicalities of organising a programme of hearings and the challenges that might need to be overcome.

Our conclusion is that where there is a considerable amount of public interest, or where the subject-matter is deeply controversial, they will help convince sceptical communities that decision-makers care enough to explore the issues openly and in public. There is even a case for holding events like this well before a consultation is launched. A pre-consultation exploration of key issues and an opportunity for stakeholder to spell out what they would like to see considered might be a first-rate way of involving the public. Used in this way, hearings can even form part of a co-production approach.

Make your own mind up by reading the latest ‘Briefing Paper 35’ which you can view here if you are member. Alternatively contact Rebecca Wright to request a copy if you are not a member, or would like Institute Associates to help prepare a programme of Public Consultation Hearings for your own organisation.

Tackling the ‘black hole’ of consultation — The Consultation Institute
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