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CLAYGATE PARISH COUNCIL RESPONSE TO ELMBRIDGE BOROUGH COUNCIL’S DRAFT STATEMENT OF COMMUNITY INVOLVEMENT CONSULTATION (July 2021)
Claygate Parish Council would like to raise concerns regarding the proposed changes to planning notifications on behalf of our local community.
The Statement of Community Involvement sets out the opportunities residents and other interested parties have to become involved in planning, and we welcome the clarity this provides local residents and the amendments that have been made over the years to help them navigate through the system.
The Cabinet minutes of 9 June acknowledged that the existing system of writing to residents to notify them of planning applications is not a perfect system, citing those letters sent to the owners/occupiers of each address are often discarded, not read and that large numbers are also returned as undelivered to the Council offices. It would be useful to have some more information on this, but that aside, we know that many local residents do value being notified by post and others have raised concerns when they have not been notified but feel they will be affected by a planning proposal.
We also acknowledge that the Planning Alert system is very helpful in engaging with residents beyond the statutory requirements alerting residents within a wider area although this is only open to those who have registered their email address.
Whilst we appreciate the need to reduce costs and make efficiencies, our main concern is that many of our residents are older, do not have an email account and do not have access to the internet which would disadvantage them if the council were to stop sending letters. (It also appears that only residents with a registered email will have received notification of this consultation and so those who do not are already disadvantaged in this respect by not being made aware of it.) We have also found that physical planning notices outside a property are not consistently and clearly displayed, some seem to “disappear”, and those affected would need to be close to the property before they were in a position to see it and may still fail to see the notification. In addition, some elderly residents are housebound making physical planning notices outside a property an insufficient means of engaging them in the process. This will therefore limit opportunities for these residents to engage in a planning application that may have a detrimental impact on them. This suggested change should be made clear in the body of the draft Statement of Community Involvement 2021 as letters are still referred to in the relevant section on page 14, rather than the changes reflected in appendix 5 only which residents may miss when reviewing the document.
In addition, there are several other points that we would like to highlight for your attention:
- There are references on pages 12 and 13 to the suggested method for pre-application consultation for developers that includes “Letter to and/or discussion with neighbours about plans”. For consistency, it would be preferable if the suggested method for EBC notifying planning applications should include “Letter to nearby neighbours”.
- Paragraph 4.2.6: We feel the clause around public consultation could be strengthened and would like to suggest this is amended to “When applicants have undertaken community consultation the Council require a full and comprehensive statement of community involvement that meets the requirements of the SCI to be submitted with the planning application in order to be able to place full weight to the contents of this consultation when arriving at a decision.”
- Paragraph 4.2.7: The second and third sentences could be open to misinterpretation regarding the role of council officers and councillors and we think it would be clearer to amend these to read as follows: “Council officers will be supportive of the principle that developers hold a pre-application consultation, but not influential at pre-application consultation events. Councillors will not give an opinion at community involvement events as this may prejudice them from taking part at the planning committee but may comment on processes.”
Paragraph 4.6.3 & 4.6.4: Both of these items state “Referrals shall be submitted within 28 days of registration.” This is an amendment from the current SCI that states “Referrals shall be submitted within 28 days of validation so it would be helpful if the reference to “registration” could be clarified as nowhere on the planning portal is there reference to a Registration Date. If the Registration Date is the date shown on the planning portal as the date that the “Consultation starts on”, then it would be straightforward to clarify this reference by amending this sentence to read “Referrals shall be submitted within 28 days of registration (or the date shown on the Planning Portal as “Consultation starts on”).
In addition, 4.6.3 states that two of the categories of planning applications which cannot be delegated to a planning officer but must be decided by the Sub-Committee are: Minor applications (1-9 dwellings or non-residential development less than 1000sqm) which are recommended for approval by officers and there are objections from 15 or more households or from Claygate Parish Council, and applications for Permission in Principle which are recommended for approval by officers and there are objections from 15 or more households. The second of these reflects the amendment made to the Constitution of Elmbridge Borough Council when in 2018 the Government introduced the system of applications for permission in principle (PIP). The result is that if Claygate Parish Council objects to a PIP application, unlike other applications this could still be decided by the planning officer without being referred to the Planning Sub-Committee. This cannot be right. We suggest that the words ‘or from Claygate Parish Council’ should be added at the end of the second category so that it reads like the first, and that when the Borough Council next has occasion to amend its Constitution the same change should be made in Part 3 of the Constitution (Responsibility for Functions) on page 35 at the end of paragraph 3 of the list of Decisions Referred to the Area Planning Sub-Committees.
Furthermore, we note that the removal of letters to local residents who may be affected by planning proposals has been driven by the desire to reduce costs to Elmbridge Council in the region of 35K per annum. The minutes of 9 June also stated that an option of only sending letters to those without a registered email address which would have seemed a reasonable option, was discounted as impossible for administrative reasons and the inflexibility of the IT system. It would seem unfair to disadvantage residents on the basis of this limitation.
For the reasons given above, we therefore ask that there are no changes made to the existing process of sending letters to residents as described in the current Statement of Community Involvement.