Mid Sussex District Council abandoned its attempt at a “core strategy” for housing development after last year’s election. The council now finds itself without a housing plan, which has been leading planning appeal hearings to find in favour of developers. One requirement for a sound district housing plan is that the council must provide for public involvement in planning decisions. Against this background, the council recently published a draft “Statement of Community Involvement” for public consultation. The Lindfield Preservation Society’s response to Mid Sussex District Council is below:
Submission for Public Consultation:
Draft Statement of Community Involvement and Planning Performance Agreements
July 2011
The Lindfield Preservation Society would like to take this opportunity to comment on the draft Statement of Community Involvement and Planning Performance Agreements recently published by Mid Sussex District Council. This public consultation comes at a worrying time for local communities. The absence of a sound five-year housing land supply has produced a planning policy vacuum in Mid Sussex that developers have been quick to exploit. We have already seen several instances in 2011 of planning permission being granted on appeal, despite determined opposition from the communities being targeted. It should be an urgent priority for MSDC to replace the current policy vacuum with a five-year land supply robust enough to survive challenges at appeal. An SCI that genuinely involves communities is in our view crucial to achieving a land supply policy that is capable of being judged as sound.
The draft Statement of Community Involvement and Planning Performance Agreement documents aim at producing a brief and understandable statement of policy, which is laudable. We feel, however, that considerable progress remains to be made in the following areas:
1) The provisions of both documents need to be more specific. General principles are fine as far as they go, but are easily ignored in practice. Each provision should be tested with the questions: Is this specific? How will it be measured?
2) How will the council be held to account? Ideally, an independent external audit would evaluate compliance annually. If performance evaluation is to be confined to an “annual monitoring report” produced by MSDC itself, there should be substantive community input into the preparation of this document in order to provide public credibility. How will the council ensure this involvement?
3) Changing behaviour is more important than changing documents. It is crucial that the principles of the draft SCI (or for that matter the existing 2006 SCI) are put into practice. We would offer one recent example of how consultation needs to be improved. On 15 October 2010 we and a group of other community organisations submitted detailed written proposals for improving the current SCI and PPA. This eventually resulted in a meeting on 4 February 2011 with Garry Wall and a group of council members and officers. We have, however, never received a substantive, detailed response to our proposals. In the interest of public consultation, we would call your attention once again to these proposals. They address each of the general points above in considerable detail. We hope they can contribute to a new SCI and PPA that are specific, measurable and for which there is full accountability. We would also ask you as a matter of courtesy to respond fully to these proposals, identifying those you will adopt and giving reasons for any that you reject.