The deadline for responding to this consultation is 22nd March. You can respond by email to planningpolicyteam.bc@buckinghamshire.gov.uk or online here : https://yourvoicebucks.citizenspace.com/planning/sci-2021/
In an earlier blog, I explained the ambit of the draft SCI and I said that I would provide a suggested response. Here is that suggested response (it uses the same numbering as the on-line response form) which I hope you find helpful:
1&2 The tick boxes from “strongly agree” to “strongly disagree” do not work well for this consultation.
You say “as a minimum we will comply with any legislation” – well that is a given requirement anyway. What you should do, is to add what you say you MAY do, to what you say you WILL do, in all sections of this consultation, notwithstanding any change in the minimum required by legislation.
You say “we will tailor our approach where needed” but then don’t say how you will “tailor” your approach.
You say you will “provide opportunities” for communities to put their ideas forward but in the succeeding sections you then limit those opportunities to too little, too late. In many cases, the public wouldn’t even have been made aware of any “opportunity” arising in order to comment on it, if your “must do” list of actions you will take, remains so restricted.
You say you will be “transparent” but this document removes transparency, for example by maybe not sending out neighbour notification letters, not using lamppost/site notices, not publishing a draft Local Plan for consultation.
Your proposals do not make the planning more accessible, they make the system less accessible and less inclusive.
You should always (not only where you think “where appropriate”) provide “clear feedback to participants” after engagement exercises. The public conception is that public responses to these consultation exercises just disappear into a black hole and are ignored.
You say you want residents to be “at the heart of what we do” – but then the SCI removes their voice by removing methods of notification of planning applications and by potentially removing the draft Local Plan consultation stage.
The planning system should not become just a digital service. This disenfranchises many and would not be visible enough because of your limited WILL DO lists (many essential actions are on your “MAY DO” lists). How would the public find out about planning applications in their town or neighbourhood if they don’t constantly search online?
3, 4 and 5 We strongly disagree that you only “may” (meaning you may not) publish a draft Local Plan for consultation. All the items you state you “MAY” do, should be moved into your “WILL DO” list – this comment applies to all sections throughout your SCI.
It is insufficient merely to publish the Publication Plan; a draft Plan must be provided for consultation at an earlier stage. Paper copies must be made available at libraries and workshops must be held.
6, 7 & 8 Strongly disagree because your “WILL” list must include your “MAY” list. In relation to SPDs, you must invite views from the general public and screen the SPD under the HRA or SEA legislation.
9, 10 & 11 You say you “may amend the boundary of the neighbourhood area if it is inappropriate” but do not say on what basis it could be deemed inappropriate nor set out a method for parishes to challenge this. Your WILL list should include your MAY list.
12, 13 & 14 Once a planning application is submitted, you MUST notify town and parish councils, not merely those with a made neighbourhood plan. You MUST display a planning notice near the application site. You MUST send neighbour notification letters. You MUST publish a press notice, you MUST notify town/parish councils, you MUST consult with Natural England, Environment Agency and all relevant consultees, you MUST publicise a weekly list via public channels (and not just digitally). During determination process, you MUST publish documents on your website AT LEAST 14 days before determination date.
15 & 16 Blank
17, 18 & 19 I am very likely to get involved in the planning process in the future.
20 The SCI is one of the most undemocratic documents I have seen. It inhibits the public from getting involved in the planning process and it inhibits visibility of planning applications, Local Plans and SPDs. Please act on these comments.
21 & 22 blank
Coming up - suggested responses to the Bucks Council Biodiversity Accounting Consultation.
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