Democracy Spraffa

Item 8 - Appendix 1

West Dunbartonshire Council · 2 August 2023
Back to Planning Committee — 2 August 2023 and its agenda

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Page 1

Effective Community Engagement in
Local Development Planning Guidance
Respondent Information Form
Please note this form must be completed and returned with your response.
To find out how we handle your personal data, please see our privacy policy:
https://www.gov.scot/privacy/
Are you responding as an individual or an organisation? 
Individual 
Organisation
Full name or organisation’s name
Phone number
Address 
Postcode
Email
The Scottish Government would like your 
permission to publish your consultation 
response. Please indicate your publishing
preference: 
Publish response with name 
Publish response only (without name) 
Do not publish response
We will share your response internally with other Scottish Government policy teams
who may be addressing the issues you discuss. They may wish to contact you again
in the future, but we require your permission to do so. Are you content for Scottish
Government to contact you again in relation to this consultation exercise?
West Dunbartonshire Council
16 Church Street, Dumbarton
0141 562 7787
G82 1QL
cameron.clow@west-dunbarton.gov.uk
Information for organisations:
The option 'Publish response only (without name)’
is available for individual respondents only. If this
option is selected, the organisation name will still
be published. 
If you choose the option 'Do not publish response',
your organisation name may still be listed as having
responded to the consultation in, for example, the
analysis report.
ITEM 8 - APPENDIX 1

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Yes  
No 
Purpose and scope
Purpose
Effective community engagement is an essential part of local development plan
preparation. This guidance sets out the Scottish Government’s high-level
expectations on how planning authorities can comply with their legal duty to engage
with the public when preparing their local development plans. It sets out the levels of
engagement that could be applied at different stages of the development plan
process.
The guidance is intended to be used by planning authorities as a sense check when
planning their engagement to support the preparation of local development plans.
It will also be helpful to communities, organisations and individuals in understanding
when they can engage in the local development plan process and what influence on
the plan making that engagement may have.
The Town and Country Planning (Scotland) Act 1997 Section 16C (introduced by the
Planning (Scotland) Act 2019) gives the Scottish Ministers the power to prepare the
guidance. It also requires planning authorities to have regard to the guidance.
Scope
The guidance sets out the levels of engagement that could be applied at different
stages of the development plan process. The guidance is not intended to detail the
approaches to or methods of engagement that may be taken at any particular stage
in the local development plan process. Approaches and methods for engagement
are in place and will continue to develop over time. It remains important that those
undertaking engagement exercises consider methods that are appropriate to the
subject, context and groups being engaged. 
To complement the guidance, we will consider opportunities to signpost examples of
engagement practice, including through the Our Place website.
Please refer to the consultation paper for further information.

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1. Do you agree that the purpose and scope of the guidance is clear? 
Yes 
No 
No view 
Comment on your answer
The scope of the guidance is clear, and West Dunbartonshire Council welcomes
that links to complementary guidance are to be included. 
Although, referring to Planning Advice Note 3/2010 is not very helpful, given it
refers to an outdated plan preparation process and outdated version of the
National Standards, which could cause confusion. We suggest that the guidance
refers to the Local Development Planning Guidance and the current National
Standards instead. Other links, such as to Our Place website, and links to
resources for engaging specific groups are also helpful.

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Levels of engagement
Different levels of engagement are appropriate to policy preparation activity. Terms
used by the International Association for Public Engagement and the National
Standards for Community Engagement help clarify how different forms of
engagement offer participants different levels of influence. The International
Association for Public Engagement terms these levels the ‘Spectrum of Participation’
((c) International Association for Public Participation www.iap2.org). This is
replicated in Table 1 of the consultation paper along with additional information on
the purpose and degree of influence these levels enable. The term ‘consult’ in this
context should not be confused with references to consultation requirements in the
Planning Act. 
The key terms related to the levels and the purpose or degree of influence of the
levels is set out below, however please refer to 'Table 1 - Levels of Engagement /
Spectrum of Participation' in the consultation paper and through the hyperlink below
for the full details:  
• engagement level - inform: purpose - to inform those with an interest in the
outcome (i.e. the public and stakeholder groups)
• engagement level - consult: purpose - to inform those making the decision or
developing proposals
• engagement level - involve: purpose - to enable participants to directly
influence the decision / options developed
• engagement level - collaborate: purpose - to share the development and
decision-making process (as much as possible)
• engagement level - empower: purpose - to hand over the ability to make
decisions and / or take action.
All the levels of engagement are a form of empowerment for communities and
planning authorities will work towards different levels of engagement depending on
the stage of the local development plan. Communicating clearly about the level of
engagement, the offer, and purpose, will help clarify and manage expectations for
everyone involved.
Communities will have most influence on the local development plan at the stages
where the engagement levels are consult, involve, collaborate or empower. This
is because at these levels planning authorities commit to being influenced by the
engagement. The reporting mechanisms set out in legislation mean that people are
given feedback on how their input has affected the approach taken.

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Please refer to the consultation paper for further information.
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? 
Yes 
No 
No view 
Comment on your answer
The “Offer to participants” at different levels of engagement do overlap making it
difficult to distinguish the practical difference between the levels in some cases.
In particular the offer to participants at the “Involve” and “Collaborate” levels
appear to be very similar. “Consult” and “Involve” also have some degree of
overlap.
It would be helpful if there was better differentiation between these levels of
engagement. Links to good practice case studies providing examples of each
level of engagement may be helpful.
There is some concern about the definition of the term “empower”, which applies
to the preparation of Local Place Plans. The offer to participants of “we will
implement what you decide” potentially sets unrealistic expectations for
communities and introduces the possibility of conflict during the plan preparation
process. As Local Place Plans are expected to be prepared for inclusion in the
published Evidence Report it is unclear how a Planning Authority or community
should proceed where there is conflict between Local Place Plans and other
evidence. The guidance should recognise this possibility, which could in part be
helped by reference to existing guidance on alternative forms of conflict
resolution, such as Planning Circular 2/2021 on the use of mediation in planning.

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Stage by stage engagement
The guidance gives further details on the local development plan stages of
preparation and the associated level of engagement, which are summarised below.
Please read the consultation paper for the full details.
• stage 1 preparing the development plan scheme and participation
statement:  engagement level - inform, involve 
• stage 2 inviting communities to prepare a local place plan:  engagement
level - inform, involve, empower 
• stage 3 preparing the evidence report: engagement level - inform, involve 
• stage 4 gate check: engagement level - consult, where necessary as decided
by the  person appointed to lead the gate check
• stage 5 preparing the proposed local development plan: engagement level -
involve, collaborate 
• stage 6 consulting on the proposed local development plan:  engagement
level - inform, consult 
• stage 7 modifying the proposed local development plan and
examination: engagement level - inform, consult, involve 
• stage 8 adopting the local development plan: engagement level - inform
• stage 9 delivery programme:  engagement level - inform, collaborate 
• stage 10 impact assessments: these are an important part of preparing the
local development plan, although listed as a stage, the guidance is clear that
the impact assessments happen throughout the plan preparation process. 
In stage 10 the guidance links the levels of engagement to the key assessments as
follows:
• strategic environmental assessment: engagement level - inform, consult
• habitats regulations appraisal: engagement level - inform
• public sector equality duty assessment: engagement level - inform, involve
• fairer Scotland duty assessment: engagement level - inform, involve
• island communities impact assessment: engagement level -  inform, consult,
involve
• child rights and wellbeing impact assessment: engagement level - inform,
consult, involve
3. Do you agree that the appropriate levels of engagement have been identified
for the stages of local development plan preparation? 
Yes 
No 
No view

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Comment on your answer 
4. Do you agree that the appropriate levels of engagement have been identified
for the impact assessments? 
Yes 
No 
No view 
Generally the levels of participation seem appropriate to each step and the level
of detail provided is helpful, with the exception of the section on modifying plans,
which appears to contradict legislation.
Under the “Modifying the Proposed Local Development Plan and Examination”
section, in the first paragraph on page 26, the guidance states that the planning
authority “may” seek an examination where representations cannot be resolved
by modification to the plan. However section 19 (1) and (2) of the Town and
Country Planning act states a local authority “are” to request an examination
where there are unresolved issues. The guidance makes this appear optional
where the legislation does not. The final version of the guidance should be
amended to reflect the legislation.
West Dunbartonshire Council would highlight the resource challenge that the
expected levels of engagement presents, and would suggest the final guidance
makes reference to the engagement undertaken being proportionate. 
It would also be helpful if there was more links to guidance on how to engage with
the many different groups required by the Planning Act 2019. This may include
guidance on the broad types of engagement that are expected e.g. where in-
person engagement might be more appropriate than electronic engagement, and
vice versa.

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Comment on your answer  
It would be useful to also include the levels of engagement expected on a Human
Rights Impact Assessment and Health Inequalities Impact Assessments, which
are not included in the lists in paragraphs 6.11 and 10.3 but are mentioned
elsewhere in the consultation document.
West Dunbartonshire Council recognise the value of the impact assessments, but
would also highlight the challenge in preparing them, particularly given the current
lack of resources in local authorities.
The assessments also potentially complicate the process for communities. It
would be helpful if the guidance could advise (or link to other advice) on how to
better integrate engagement on impact assessments with the Development Plan
engagement, to avoid consultation fatigue. Engaging with the local planning
process can be demanding, especially for the hard to reach groups that the
impact assessments are designed to benefit. Advice on good practice to reduce
the demand on communities engaging with the process would be helpful.

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Further consultation questions
Further questions about the consultation paper and the associated impact
assessments that have informed it are provided to encourage additional comments
to be made.
Please refer to the impact assessments report.
5. Overall, is the approach set out in the guidance helpful? 
Yes 
No 
No view 
Comment on your answer 
6. Do you have any views about the initial conclusions of the impact
assessments that accompany and inform this guidance? 
Yes 
No 
No view 
Comment on your answer 
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? 
Yes 
No
The structure and level of detail within the guidance is helpful, with some
additional clarity needed, as set out in our answers to other questions.

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No view 
Comment on your answer 
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? 
Yes 
No 
No view 
Comment on your answer 
9. Please provide any further comments on the guidance set out in this
consultation.
Please provide comments here 
The guidance makes specific reference to protected characteristics and how
people with protected characteristics should be involved in development planning,
and impact assessments, which is positive. 
One of the principles of the guidance is that it will support opportunities to avoid
or reduce consultation fatigue by linking to other processes. 
West Dunbartonshire Council does not believe the guidance succeeds in this
regard. This is highlighted in our answer to question 4 on impact assessments,
but the issue also extends to other pieces of work Local Development Plans rely
on as part of their evidence base, listed in table S2. Additional guidance on the
engagement processes for these strategies could compliment overall
engagement on the Local Development Plan.