GETTING INVOLVED IN PLANNING: ANALYSIS OF CONSULTATION RESPONSES
CHAPTER TWO: THE CONSULTATION EXERCISE
DISTRIBUTION ARRANGEMENTS
2.1 The Scottish Executive Planning Division issued a total of 10,350 consultation documents, comprising 1,798 main papers, 2,428 questionnaires and 6124 easy-read booklets. It has only been possible, given the distribution of multiple copies to some organisations, to identify 1180 separate bodies and individuals, who are known to have received the consultation documents. Altogether 405 submissions were received in response to the consultation, but there were 3 responses where additional comments were received, which meant that 402 unique responses were received in practice. Twenty-nine additional responses were received after the closing date for submissions, and while they have not formed part of this analysis their views will be taken into account by the Executive.
2.2 The figure of 402 responses was significantly higher than other recent planning consultation exercises. It appeared that the direct contact with Community Councils, the availability of the documents on internet, the wide distribution of questionnaires, the availability of the easy-read booklet and the ability to e-mail comments, all had a positive effect on the overall number of returns.
STAKEHOLDER GROUPS
2.3 Consultees were assigned to one of 6 broad stakeholder groups, all of which had further subdivisions to allow a more refined analysis. Table 2.1 shows the 6 groups and the 13 detailed stakeholder categories used for this purpose. There were 18 anonymous responses received before the deadline. These have been categorised as private individuals.
Table 2.1 Definition of Stakeholder Categories
Broad Stakeholder Group | Detailed Stakeholder Group |
1. Local Authorities | 1.1 Local Authorities |
1.2 Joint Committees etc. |
2. Public Bodies | 2.1 Non Departmental Public Bodies |
2.2 Other Public Bodies |
3. Businesses and Trade Organisations | 3.1 Development Industry |
3.2 Other Businesses |
4. Professional and Academic Bodies | 4.1 Professional Organisations |
4.2 Universities and Research Units |
4.3 Planning Consultants, Architects and Lawyers |
5. Voluntary Sector | 5.1 Community Councils and Associations |
5.2 National and Local Voluntary Organisations |
6. Public and Politicians | 6.1 Private Individuals |
6.2 Politicians and Political Parties |
RESPONSE RATES
2.4 Given that 10,350 documents were distributed but only 1180 named recipients could be identified, it is not possible to calculate a reliable overall response rate. However, in 3 of the 6 categories (Local authorities, and to a lesser extent, Public Bodies, and Professional/Academic Bodies), the base population is sufficiently accurate to be able to calculate a meaningful level of response. A detailed breakdown of responses by broad category of respondent is shown in Table 2.2 below.
Table 2.2 Consultation Response Rates by Stakeholder Group
Stakeholder Group | Total Sent Out | Total Replies | Unsolicited Replies | Overall Group Response Rates |
Number | % Share | Number | % Share |
Local Authorities | 36 | 32* | 8% | 0 | 0% | 89% |
Public Bodies | 68 | 13 | 3% | 2 | 15% | 19% |
Businesses & Trade Orgs | 104 | 20 | 5% | 11 | 55% | 19% |
Professional and Academic Bodies | 158 | 12 | 3% | 4 | 33% | N/a |
Voluntary Sector | 457 | 164 | 41% | 119 | 73% | N/a |
Public and Politicians | 356 | 161 | 40% | 144 | 89% | N/a |
Totals | 1180 | 402 | 100% | 280 | 70% | N/a |
*Note: 30 local authorities and 2 LA committees responded before the deadline. 2 responses from the remaining local authorities arrived after the deadline and these were analysed separately by the Scottish Executive along with other responses received after the deadline.
2.5 The main points of note from the Table are, first, the dominance of the voluntary sector and public in the total response. While their true response rates would be much lower than those indicated, a significant body of opinion from these two sources has been received. As suggested earlier, this has been assisted by specific efforts to contact Community Councils and the use of questionnaires. Second, there was a high response from Local Authorities and many of the proposals clearly do have significant operational and resource implications for planning authorities. Third, the level of response from Public Bodies and Businesses was lower. However, the level of response from the Professional/Academic sector was lower still, although all of the key representative professional bodies did respond in detail. It is not clear why the response from these groups was lower than in previous exercises, although the emphasis on technical development control procedures in the consultation document may have had some inhibiting effect. Overall, there was a considerably skewed distribution of responses across the 6 main stakeholder categories but, nonetheless, it is considered that a reasonably good cross section of interested opinion has been received.
2.6 Not all respondents answered all of the 32 Questions in the consultation document. Fifty two respondees (13%) made either general comments or raised additional matters but did not specifically answer any of the questions posed. One hundred and ten respondents (27%) raised additional matters, and 80 of these concerned Third Party Right of Appeal, which, while referred to in the consultation document, was not associated with a specific question. Table 2.3 gives a detailed breakdown of responses by stakeholder category for each question. Responses to the specific questions varied from 350 (87%) for Question 1 about the need for local planning policy forums to 85 (21%) for Question 12c which asked whether local authorities should serve both advertisement and enforcement notices, if they were to be introduced. Most questions had a very healthy response rate in the range 75% - 85%.
Table 2.3 Responses to Questions by Stakeholder Category
Question Number | Local Auth | Public Bodies | Busi-nesses | Prof &Acad | Vol Bodies | Public | Total |
No. | % |
Overall Response Rate | 8% | 3% | 5% | 3% | 41% | 40% | 402 | 100% |
Q1. Local Forums | 9% | 3% | 5% | 3% | 41% | 39% | 350 | 87% |
Q2. Policy Notification | 9% | 3% | 5% | 3% | 40% | 40% | 347 | 86% |
Q3. Independent Reporter | 9% | 2% | 5% | 3% | 40% | 40% | 337 | 84% |
Q4. Binding Recommnds | 9% | 3% | 5% | 3% | 41% | 40% | 337 | 84% |
Q6. Standard App Forms | 9% | 3% | 6% | 3% | 40% | 40% | 338 | 84% |
Q7a LA Notification | 9% | 2% | 6% | 3% | 40% | 40% | 339 | 84% |
Q7b Increase Fees | 9% | 1% | 5% | 3% | 40% | 42% | 270 | 67% |
Q7c Research Costs | 22% | 4% | 7% | 7% | 37% | 23% | 97 | 24% |
Q8. LA s to publicise | 9% | 2% | 5% | 3% | 40% | 41% | 324 | 81% |
Q9. All apps the same | 9% | 2% | 5% | 3% | 39% | 42% | 317 | 79% |
Q10. Improve notice/plan | 9% | 3% | 5% | 3% | 40% | 40% | 323 | 80% |
Q11. 21 day notification | 9% | 3% | 5% | 3% | 40% | 41% | 341 | 85% |
Q12a Notify ads/enforcmt | 9% | 3% | 5% | 3% | 39% | 41% | 311 | 77% |
Q12c LA s serve both | 24% | 4% | 8% | 8% | 9% | 6% | 85 | 21% |
Q14. Edinburgh Gazette | 9% | 2% | 5% | 3% | 41% | 40% | 327 | 81% |
Q15. LA s to publicise | 9% | 2% | 5% | 3% | 41% | 40% | 327 | 81% |
Q16a Weekly List | 9% | 2% | 5% | 3% | 40% | 40% | 335 | 83% |
Q16b Free to amenity socs | 22% | 4% | 7% | 5% | 36% | 26% | 129 | 32% |
Q17. 21 days for reps | 9% | 3% | 5% | 3% | 40% | 40% | 336 | 84% |
Q18. Departure costs | 9% | 2% | 5% | 3% | 40% | 40% | 321 | 80% |
Q19. Listed building ads | 21% | 4% | 9% | 7% | 36% | 21% | 137 | 34% |
Q20. Site Notices | 10% | 2% | 5% | 3% | 41% | 40% | 315 | 78% |
Q21. Responses open | 9% | 2% | 5% | 3% | 40% | 40% | 336 | 84% |
Q22a Electronic comments | 9% | 2% | 6% | 3% | 39% | 41% | 323 | 80% |
Q22b National form | 9% | 3% | 5% | 3% | 40% | 40% | 324 | 81% |
Q22c Publicly available | 9% | 2% | 5% | 3% | 40% | 41% | 318 | 79% |
Q23. Decision factors | 9% | 2% | 6% | 3% | 39% | 42% | 345 | 86% |
Q24. Decision text | 9% | 2% | 6% | 3% | 40% | 41% | 339 | 84% |
Q25a Info on Agreements | 9% | 2% | 6% | 3% | 39% | 41% | 323 | 80% |
Q26. 2 months for Appeal | 9% | 2% | 6% | 3% | 39% | 41% | 337 | 84% |
Q28a Enforcement Notices | 9% | 2% | 4% | 4% | 42% | 39% | 317 | 79% |
Q28b Other changes | 10% | 2% | 3% | 3% | 41% | 43% | 239 | 59% |
Q29a Mediation | 10% | 3% | 5% | 3% | 40% | 41% | 311 | 77% |
Q30. Consultative Group | 9% | 2% | 5% | 2% | 41% | 40% | 318 | 79% |
Q31. Electronic Group | 9% | 2% | 5% | 3% | 40% | 41% | 324 | 81% |
Q32. Helplines | 9% | 2% | 5% | 3% | 42% | 37% | 311 | 77% |
Note 1: The percentages against stakeholders represent the share of total responses to each question
Note 2: The percentage in the final column shows the share that the total responses to each question represents of all responses (402)
Note 3: Figures do not always sum to 100% due to rounding.
2.7 Comparing the overall response rate for each separate stakeholder group with their rate for individual questions does not reveal significant variations, other than for the questions omitted from the questionnaire (Q7c and Q12c). Local authorities have higher rates for all questions. This is because nearly all of the local authorities answered all of the questions. They were followed by Business respondents, but none of the groups were particularly selective in their responses.
COMMENTS ON THE CONSULTATION EXERCISE
2.8 In general, the method of conducting the consultation exercise was welcomed by all of the various parties. As previously indicated, the opportunity to submit comments by e-mail and questionnaire encouraged responses, particularly from the public and voluntary sector, who had not responded to previous consultation exercises. A minority of respondents stated that they had only become aware of the exercise late into the consultation period. However, it appeared that the extension to April 26 th helped obviate any difficulties which this might have caused.
2.9 There were also a few comments about the questionnaire itself. These included: discrepancies between the questionnaire questions and those in the consultation document, the ability to respond other than "yes" or "no" to the questions and a view that the questions were generally phrased in a way which would encourage a "yes" response. There were also a number of complimentary remarks about the range and layout of the consultation documentation and overall the exercise was undertaken in a reasonably effective manner.
2.10 The consultation exercise was welcomed by most of the respondents in each of the stakeholder groupings. Reasons in support of the review included problems of delay and bureaucracy; a system lacking resources and under pressure and one which was not "fit for purpose" and in need of radical overhaul. However, there were a few contrary views to the effect that a lack of confidence in the current system had not been demonstrated and that further change to the planning system at this juncture would not be helpful.
2.11 Respondents did not generally comment on the scope of the review, but the small number who did tended to be critical. One business consultee wanted the review of the planning system to be conducted, "… comprehensively, and not in the distinctly separate and staggered exercises currently being undertaken". Others drew attention to the need to see the review in the context of the Review of Strategic Planning, and there was a view that it was "premature" until decisions on that review had been made. There were also some concerns that the review was too focused on development control and there were more important concerns with the development plan system which required to be addressed. One planning consultant considered that the proposals, " are tinkering around the edges of the system". Overall, however, most respondents welcomed the opportunity to submit their views on a range of issues which were acknowledged to be important facets of the current operation of the planning system.