Effective community engagement in local development plans: consultation response summary

Summary of Responses to Questions

Question 1

Do you agree that the purpose and scope of the guidance is clear?

Responses to Question 1 by respondent category are set out in Table B.

Table B

Classification	Yes	No	No view	Not answered
Business/business representative organisation	4	2	-	-
Community council	5	-	-	-
Individual	4	8	1	-
Local authority	14	1	-	-
Membership organisation	4	-	-	1
Public body	4	-	-	1
Third Sector	4	2	2	2
Total	39 (66.1%)	13 (22.0%)	3 (5.1%)	4 (6.8%)

55 respondents answered this question with the majority agreeing that the purpose and scope of the guidance is clear. The high number of additional comments received suggested that there were qualifications to be made to the views offered.

Respondents highlighted the importance of framing and defining the purpose of engagement and a commitment to collaborative approaches to build accountability, trust, and relationships between organisations, communities, and people. Responses received called for clarity around the intended audience, and suggested this should include all stakeholders, investors, developers, and non-geographical interest groups.

Question 2

Do you agree that the terms inform, consult, involve, collaborate, and empower, as described in the table, are helpful terms to support understanding of different levels of engagement and the influence that results from it?

Responses to Question 2 by respondent category are set out in table C.

Table C

Classification	Yes	No	No view	Not answered
Business/business representative organisation	3	2	1	-
Community council	3	1	1	-
Individual	5	7	1	-
Local authority	6	8	-	1
Membership organisation	4	-	-	1
Public body	4	-	-	1
Third Sector	5	2	1	2
Total	30 (50.8%)	20 (34%)	4 (6.7%)	5 (8.5%)

54 respondents answered this question. A majority of respondents agreed that the terms of the levels were helpful, and of those who disagreed some provided further comment that indicated general support, while raising specific points

Some respondents commented on the context and aims, essentially seeking strengthening the context that reinforces the purpose and use of the guidance, a greater clarity on the aims of the guidance and levels of engagement. Public body category respondents noted that there are already operating standards and approaches to community engagement.

The Levels

Respondents called for clearer differentiation between the levels. There were calls to remove some levels or include others and suggestions for alternative titles. Expectations management was a common theme, with respondents suggesting that the ‘offer to participants’ should provide clarity around the handling and taking account of individual concerns and aspirations and the weighting of decisions against this. Responses noted that there may be non-local development planning routes for handling concerns and aspirations and planning authorities won’t be the only organisations implementing decisions made by communities.

‘Consult’

Respondents suggested a particular need for clarity around the definition of ‘consult’ that differentiated from the use in the Planning Act. It was suggested that the purpose should recognise views offered, to help decision makers weight them in decisions and that the ‘offer to participants’ should be more clearly differentiated from the ‘involve’ level.

‘Involve’

In relation to expectations management, respondents suggested that the level may over-reach in terms of what the planning system can achieve when handling contributions offered. It was suggested that the ‘offer to participants’ clarify that a wide range of views are handled as part of the process, that themes are addressed rather than individual concerns and aspirations and that not all views will be reflected in outcomes.

‘Collaborate’

Some respondents from the individual, local authority, and third sector categories commented on this level. Concerns about expectations management and clarity around what can be included in a local development plan was raised by a few local authority category respondents. It was suggested by Community Learning and Development Standards Scotland that the level should aim to create a ‘more equal partnership’.

‘Empower’

Many respondents commented on this level here and elsewhere in the consultation. The majority of respondents to this question were from the local authority category, others were from the business/business representative, public body, and third sector categories. Almost all of the respondents were identifying concerns around expectations management most likely for the ‘offer to participants’, with some repeated expressions being ‘misleading’ and ‘over-promise’.

There was concern that not all local authorities will be comfortable with delegation and not all communities will have the capacity to take on decision making responsibilities. It was suggested that the text may indicate that local authorities would provide resources for local place plans, and that it goes beyond the legislative requirements for planning authorities to take local place plans into account in the preparation of local development plans.

Suggestions for change for this level included:

• examples of outcomes where empowerment has been taken forward
• align the description with legislative requirements for local place plans
• clarify not all community decisions can be supported or implemented as a range of considerations need to be included in decision making, one suggestion to link more closely with the wording of Circular 1/2022 ‘Local Place Plans’
• link to Circular 2/2021 ‘Guidance on the Promotion and use of Mediation in the Scottish Planning System’
• clarify the local authority role

The potential outcomes of the draft guidance were raised in the consultation. Supportive comments included noting the potential for improved engagement practice. More negative comments noted the potential for people to be disenfranchised by poor engagement that lacks transparency, the undermining of the approach where local decisions are overturned by Government, and a concern that only ‘consult’ will be achieved. Suggestions about monitoring the guidance and local place plans were also made. Other points included noting that community empowerment isn’t felt strongly at present.

Question 3

Do you agree that the appropriate levels of engagement have been identified for the stages of local development plan preparation?

Responses to Question 3 by respondent category are set out in Table D.

Table D

Classification	Yes	No	No view	Not answered
Business/business representative organisation	2	2	1	1
Community council	3	2	-	-
Individual	4	8	1	-
Local authority	11	2	1	1
Membership organisation	3	-	-	2
Public body	2	1	-	2
Third Sector	2	4	-	4
Total	27 (45.7%)	19 (32.2%)	3 (5.1%)	10 (17.0%)

49 respondents answered this question.

Comments were received across the range of respondent categories in relation to the stages as a whole. These included being clear about the impacts and duration of engagement and providing further information about or make additions to the stakeholder lists. It was thought that intersectional matters could be better addressed in relation to language used, climate change risks and that poverty could be addressed more effectively.

Many responses to this question also suggested removing some levels or stages, including additional or other levels or stages and suggestions for alternative titles.. The responses were generally supportive or expressed support for specific elements. Suggested changes in relation to the levels included, applying the more influential levels to more stages, drawing out the connection with the Place Principle, providing examples of engagement and more information about stakeholder control and influence.

A few respondents from the community council and third sector categories made points related to cultures within the planning system and power imbalances that could affect implementation of the guidance.

The Stages

Beyond the more overarching points, comments were made in the consultation about the individual stages of local development plan preparation, how the levels applied to them, on engagement levels perceived to be missing from stages, on the timing of the stages, and how alternative wording could better promote an understanding of obligations and promote ambition.

Stage 2: Evidence Gathering - Inviting Communities to Prepare a Local Place Plan:

Respondents felt there was a potential limitation on empowerment at this stage and for communities to be disenfranchised which could be addressed with feedback to communities. It was suggested that the guidance should identify the frequency and timing of the local place plan invitation, including the timing of registering of local place plans. That the impact of a local place plan on a local development plan is the empowerment not the local place plan itself.

A few comments received from local authority, membership organisation and third sector categories, commented on the assistance, resources and support for local place plan preparation and the publication requirements. These responses sought more detail on the range of support and resources available and how this would be made available.

Stage 3: Preparing the Evidence Report:

Respondents suggested the draft guidance was not clear in its encouragement of feedback for stakeholders relating to specific proposals that are for consideration in the proposed plan. There were also comments made on the stakeholder list provided.

Stage 4: Gate Check:

A few respondents from the local authority and third sector categories made comments that were about the processes associated with the Gate Check, which are beyond the scope of the guidance although connected in broad terms to engagement transparency overall. A suggested change in relation to engagement was to include information on communication of the gate check assessment report to stakeholders.

Stage 5: Preparing the Proposed Local Development Plan:

There were calls within the responses for more ambition and that this stage;

‘should go beyond information provision and consultation and promote innovative, pro-active engagement’ (Scottish Community Development Centre).

Stage 6: Consulting on the Proposed Local Development Plan:

Consultees asked that the guidance support proactive engagement and clarify the stage at which stakeholders have the opportunity to comment on or oppose a local development plan.

Stage 7: Modifying the Proposed Local Development Plan and Examination:

One change suggested for this stage included encouraging planning authorities to give full consideration to the mechanism, highlighting the benefits of modifying the plan at this stage to minimise conflict, reduce length and complexity of examinations, improving robustness of the LDP.

Other points

A range of points were made by a few respondents from the individual, local authority, and public body categories, as follows:

• exclusion from a process can lead to frustration
• additional guidance is needed for stakeholders about engagement they may need to undertake to ensure a broad range of views are included in local development plan preparation
• provide more information about planning processes – to build capacity of those unfamiliar with the planning system
• that text heavy approaches are not good for engagement.

Question 4

Do you agree that the appropriate levels of engagement have been identified for the impact assessments?

Responses to Question 4 by respondent category are set out in Table E.

Table E

Classification	Yes	No	No view	Not answered
Business/business representative organisation	1	-	3	2
Community council	3	1	1	-
Individual	5	8	-	-
Local authority	13	-	1	1
Membership organisation	1	-	2	2
Public body	3	-	-	2
Third Sector	2	4	1	3
Total	28 (47.5%)	13 (22.0%)	8 (13.6%)	10 (16.9%)

49 respondents answered this question.

Just under half of respondents agreed that the appropriate levels of engagement had been identified for the impact assessments. The community council, local authority (in particular) and public body category respondents tended to agree that the right level of engagement had been identified for the impact assessments. Individual and third sector category respondents tended not to agree that the right levels had been identified.

General comments

Some respondents from the individual, local authority, public body and third sector categories indicated support for the levels in relation to the impact assessments, with a few respondents giving views on the levels identified for particular impact assessments. It was also suggested by a few individual respondents that the levels approach was too complex. Lack of local authority resource was highlighted as an obstacle to the preparation of impact assessments.

Impact assessments

Tables 3 and 4 of the draft guidance were about the impact assessment process in relation to the local development plan stages, and levels of engagement associated with impact assessments. A few respondents from the local authority and third sector categories made the following suggestions:

• the guidance should clarify whether the levels were for the impact assessments or the local development plan;
• there should be a consultation stage of the draft environmental report ahead of the proposed plan;
• an Equality and Human Rights Impact Assessment should be included.
• Health Inequalities Impact Assessment should be included
• Other suggested changes included:
• include legal obligations in Stage 10;
• promote a human-rights based approach throughout the guidance
• include support and resources for stakeholders to consider climate issues
• guidance on when and how the levels should be used
• definitions of ‘early engagement’, ‘involvement’ and of the levels
• review language in relation to inclusion and accessibility

Question 5

Overall, is the approach set out in the guidance helpful?

Responses to Question 5 by respondent category are set out in Table F.

Table F

Classification	Yes	No	No view	Not answered
Business/business representative organisation	2	-	3	1
Community council	3	-	2	-
Individual	4	8	1	-
Local authority	13	1	1	-
Membership organisation	3	-	-	2
Public body	4	-	-	1
Third Sector	3	2	2	3
Total	32 (54.2%)	11 (18.6%)	9 (15.3%)	7 (11.9%)

52 respondents answered this question.

A little over half of respondents thought the approach was helpful. Most of the local authority and public body category respondents agreed, and more than half of the community council and membership organisation category respondents agreed. More than half of the individual category respondents did not agree. Given the lower levels of agreement to application of the levels of engagement to the stages of local development plan preparation (Question 3) and impact assessments (Question 4), the more positive response to question 5 may suggest that there is some support for the approach but that some details need to be considered further.

General comments

In relation to the aims, and approach of the guidance some respondents across the range of categories indicated their support in particular for the:

• aims, including for transparency
• framework approach
• levels and stages
• inclusivity
• identification of planning authority responsibilities

There was a general view across respondent categories that the guidance was aligned to other relevant guidance and strategies and served as a sense check or a vehicle for raising awareness. A few respondents from the individual and third sector categories made Comments indicating why they thought the guidance would not be helpful, suggestion it was unlikely to create change, was too complicated, that the aims were unclear, didn’t respond to community experiences, was controlling.

Clarity

Across the categories, the views on how clear the draft guidance was, were split. The qualitative responses echoed responses to other consultation questions that the aims needed to be more aspirational, greater clarity was needed and, that more definitions were needed.

Purpose

A few respondents suggested changes to the guidance that related to its purpose as a means to secure relevant information from communities and contribute to preventative spending in health and wellbeing - through the promotion of more meaningful engagement and the benefits of better community engagement

Accountability

Points made about accountability are summarised at the front of this document, slight variations beyond those previous points included that the guidance lacked compliance requirement. A suggested change was that the guidance should include information on how to hold planning authorities and statutory bodies to account.

Other points

Suggestions were received for additional elements for the guidance including:

• reference to the Local Living and 20 Minute Neighbourhoods Guidance
• strengthened links to the Place Principle
• change the Spectrum of participation table and stage by stage section to address methods and rationale for engagement or to create a structure more around the National Standards for Community Engagement
• use a clearly anti-racist approach
• strengthen the human rights based approach
• highlight planning authority duties under the Public Sector Equality Duties

Question 6

Do you have any views about the initial conclusions of the impact assessments that accompany and inform this guidance?

Responses to Question 6 by respondent category are set out in Table G.

Table G

Classification	Yes	No	No view	Not answered
Business/business representative organisation	1	-	3	2
Community council	1	1	3	-
Individual	5	7	1	-
Local authority	3	3	9	-
Membership organisation	1	-	2	2
Public body	-	2	1	2
Third Sector	3	-	2	5
Total	14 (23.7%)	13 (22.0%)	21 (35.7%)	11 (18.6%)

48 respondents answered the question.

The largest proportion of respondents expressed no view, although more than a fifth indicated they did have views on the impact assessments, from all categories except the public body category.

General comments

Some general comments were made by respondents on the conclusions of the impact assessments. A few comments mentioned the importance of not supporting a box ticking approach to impact assessments, a more equal focus on the views of communities and the need to change the outcomes as a result of the assessments.

Others commented on the specifics of some issues highlighted by individual impact assessments, including the need to focus on barriers to engagement faced in island communities, and that Equality and Human Rights Impact Assessments should be required as part of engagement activity.

Resources and capacity

Respondents from the local authority and membership organisation categories commented on resources, their points included:

• concern about the cost of engagement
• concern about the cost of LDP preparation
• concern about capacity for undertaking engagement and analysis;
• concern about local authority ability to make up for the lack of local place plans in some communities, which could signal an inequality within the system;
• that there are some funds for communities, but a national fund should be established for local place plans.

Other points

Other points were made by respondents from a range of categories include:

• that an alternative approach is needed to generate changes to power structures and engagement
• a request for an equality impact assessment for planning applications
• a request for early communication to developers of matters raised by communities, to assist in the preparation of major development proposals
• that engagement with community councils is not necessarily representative of community views
• that better engagement will lead to better LDPs
• that the planning system should prioritise local services for successful local economies.

Question 7

Thinking about the potential impacts of the guidance – will these help to advance equality of opportunity, eliminate unlawful discrimination, and foster good community relations, in particular for people with protected characteristics?

Responses to Question 7 by respondent category are set out in Table H.

Table H

Classification	Yes	No	No view	Not answered
Business/business representative organisation	-	-	5	1
Community council	2	1	1	1
Individual	4	7	2	-
Local authority	11	3	1	-
Membership organisation	1	-	2	2
Public body	2	-	1	2
Third Sector	1	3	2	4
Total	21 (35.6%)	14 (23.7%)	14 (23.7%)	10 (17.0%)

49 respondents answered the question.

Over a third of respondents, felt the guidance would help to improve equalities and relations, while just under a quarter did not agree. Respondents from all categories answered the closed question. Local authority category respondents tended to agree, individual category respondents tended to disagree.

Positive comments were offered by some, about the potential impacts of the guidance. The possibility of the guidance to have a role in raising awareness was identified and it was suggested that identifying engagement opportunities could be noted in the participation statement and evidence report, including highlighting the importance of engaging people with protected characteristics.

Some respondents from the community council, local authority, and third sector categories felt more negatively or uncertain about the impacts - noting a lack of Equality and Human Rights Impact Assessments being carried out and the missed opportunity to reference the public sector duties in the guidance.

A general lack of community empowerment was raised and there were calls for increasing support for bottom up approaches and the community ability to resist policies that undermine equality, and equal rights of appeal. The issue of organisational culture in relation to trust in communities was also raised.

Question 8

Do you have evidence that can further inform the impact assessments that accompany this guidance, in particular in relation to the impact of the guidance on people with protected characteristics, businesses and costs to businesses?

Responses to Question 8 by respondent category are set out in Table I.

Table I

Classification	Yes	No	No view	Not answered
Business/business representative organisation	1	1	2	2
Community council	1	2	2	-
Individual	3	6	4	-
Local authority	1	9	4	1
Membership organisation	-	1	2	2
Public body	1	1	1	2
Third Sector	3	-	4	3
Total	10 (17.0%)	20 (33.8%)	19 (32.2%)	10 (17.0%)

49 respondents answered the question.

Many respondents provided comments with direct evidence to inform the Impact Assessments including experiences of engagement. Where additional evidence was provided it appeared to be focused on the Equalities Impact Assessment.

Equalities Impact Assessment

A few respondents from the third sector category identified evidence sources, including:

• Involving Ethnic Minority Communities in Equality Impact Assessments
• Age Scotland National Housing Survey 2023
• Age Scotland Big Survey 2023
• Transforming participation for disabled people in Glasgow beyond Covid 19
• Budgeting for Equality
• Girls’ Attitudes Survey 2023
• Young People’s Participation in Decision Making: UK 2022 Survey Report
• All In for Change
• Fairer Scotland Duty should be combined with equality impacts to avoid marginalisation of people with protected characteristics

Other points

The following points were made in relation to the guidance specifically:

• it should not add complexity to engagement
• it should manage expectations of engagement
• it should support a shift to community-led engagement.

The following assessments were recommended:

• Equalities and Human Rights Impact Assessment
• Health Impact Assessment.

Question 9

Please provide any further comments on the guidance set out in this consultation.

Responses to Question 9 by respondent category are set out in Table J

Table J

Classification	Comments	No comments
Business/business representative organisation	3	3
Community council	2	3
Individual	6	7
Local authority	9	6
Membership organisation	5	-
Public body	3	2
Third Sector	4	6
Total	32 (54.0%)	27 (46.0%)

A little over half of respondents from all respondent categories indicated they had further comments to offer. The majority of themes raised in response to this question have been addressed in elsewhere in this summary. Additional points relate to the connection between local development plan engagement and onward discussions about sites, and suggestions for some information sources cited.

General support and clarity

General support for the guidance was offered by many respondents across the categories. This included support for particular elements and a wider indication that the guidance offered clarity. The potential for the guidance to support improving collaborative approaches, was also noted.

Less supportive points

A number of respondents made points that had essentially been addressed in responses to other questions of the consultation, the themes raised included:

• trust and relationships
• wellbeing and consultation fatigue
• capacity and resources including reference to needing input from environmental experts in LDP preparation, and the role of Planning Aid Scotland Successful Planning = Effective Engagement and Delivery guidance and training offer for planning authorities, as additional points to those made elsewhere in response to the consultation
• including some particular aspects: climate change, biodiversity, mediation, equal representation
• levels of engagement.

Stakeholders

A few respondents commented on who should be involved in engagement, suggested changes for groups to include not previously listed in response to other questions included:

• community groups/representatives (to be engaged with by planning authorities and councillors)
• seldom heard groups
• non-geographic interest groups
• Community Learning and Development workers and volunteers.

Further suggestions of references for inclusion in the guidance

A few respondents from the local authority and the membership organisation categories suggested further references for inclusion:

• Local Outcome Improvement Plans
• relevant sections of the Local Development Planning Guidance
• National Occupational Standards for Community Learning and Development practice
• Community development practice standards (International Association for Community Development)
• Outcomes from the Public Sector Equality Duty review

Editing points

A public body category respondent made points to clarify or sought clarifications for specific wording in particular in sections.

Additional references provided for information (links provided were not always accessible so have been identified separately):

• Responsive, supportive and resilient communities: A review of community development during the pandemic
• Competent Practitioner Framework
• Community Engagement and Participation Guidance
• How to do a community audit: building profiles using neighbourhood statistics
• Community Profiling in West Dunbartonshire – What works in Community Profiling?
• Strategic guidance for community planning partnerships: community learning and development
• Scotland’s Census 2022
• Council Area Profiles
• Rural Scotland Key Facts 2021
• Participatory Budgeting Resource Hub
• Local living and 20 minute neighbourhoods guidance Consultation Draft (final version now published)