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Comment

Draft Statement of Community Involvement 2016

Representation ID: 34504

Received: 16/05/2016

Respondent: Rapleys

Representation Summary:

In addition, the 'comments form' should be provided as a WORD document in order that the representations can be drafted and issued to clients, prior to them been formally submitted to RDC.

Full text:

These representations to the draft Statement of Community Involvement (2016) have been submitted on behalf of Aber Ltd, A. W. Squier and D. W. Squier (who jointly own a site off Ashingdon Road):

2 Planning Policy

Notification and Engagement Techniques

Para. 2.3 It is considered that there is still scope to provide more engagement with harder to reach groups (e.g. ethnic minorities and the youth). In order to reach these groups Rochford District Council ('RDC') should consider using organisations which specialise in soft communication skills, to reach these groups, as often their views are not captured as part of the Local Plan process.

Submitting Comments
Para. 2.5 Agree with the proposed methods for people to submit their comments.

Para. 2.8 In addition, the 'comments form' should be provided as a WORD document in order that the representations can be drafted and issued to clients, prior to them been formally submitted to RDC.

Consultation Feedback
Para. 2.11 Agree, that a key part of community involvement is the preparation of a report to demonstrate what consultation was undertaken, a summary of the comments received and critically how these comments have been addressed. This is
considered to be important to demonstrate the transparency of the process.
Community Infrastructure Levy (CIL) Charging Schedule - Who, How and When

Para. 2.17 Within the table, under the Section that deals with Evidence Base Preparation, with regards the 'engagement opportunities', it does not advise how RDC will select the agents and developers, in order to undertake their targeted engagement. It would be appreciated if further information could be provided in respect of the selection of the agents / developers for the targeted engagement; furthermore, we would be keen to be involved in this process.

Supplementary Planning Documents - Who, How and When
Para. 2.19 Within the table, under the Section that deals with Regulation 13, with regards 'engagement opportunities', it is considered that events / exhibitions should be considered to be an appropriate publicity and engagement technique.

3 Planning Applications
Para. 3.1 In terms of the reference to applications for Lawful Development Certificates, while we would agree that there is little benefit in consulting applications for proposed use or development. This is not necessarily the case for applications for 'existing use or development', as neighbouring properties may be able to provide useful information into the background of the site / development.

Pre-Application Advice
Para. 3.3 We would agree that pre-application advice is particularly beneficial when
developing major applications. In addition, the involvement of Members would
further assist in refining the proposals prior to their formal submission and
determination by Committee.

Para. 3.5 We would agree that RDC should not undertake public consultation as part of a pre-application submission, as these discussions should be kept confidential. Instead when appropriate, the applicant will undertake its own public consultation exercise, which would then be summarised in the Statement of Community Involvement, which will form part of the planning application.

Pre-Application Consultation
Para. 3.6 Prior to the submission of a major planning application proportionate preapplication consultation should be undertaken with the local community.

Para. 3.7 In terms of the listed benefits for consulting affected communities, under the third bullet, in addition to public meetings, we would highlight the particular benefit of public exhibitions, where it is possible to get a range of the project consultants to attend in order to respond to specific questions.

Para. 3.8 We would comment that a key aspect of the pre-application consultation with RDC is to obtain their advice on the level and method of public consultation that should be undertaken, including which stakeholders / local groups should be particularly consulted about the proposals.

Para. 3.9 It is considered that dependent upon the proposals there would be benefit in consulting organisations like the County Council, Heritage England, Environment
Agency and Natural England for advice on their development proposal. As part of
their pre-application advice RDC should provide advice on the need to consult with
these organisations.

Planning Performance Agreements
Para 3.10 We consider that the benefits of a planning performance agreement should be highlighted in response to the initial pre-application request to major / strategic development proposals.

Planning Applications
Para 3.11 We would advise that given that most people would view planning application on RDC's website as opposed to visit the planning department, the details on the website should be compliant with the planning authority's requirement to maintain a statutory register of applications under consideration and planning decisions.

Para. 3.12 The second bullet deals with the issue of site notices and we consider that in addition to just referring to major applications, particular reference should also be made to applications accompanied by an EIA, those affecting rights of way and departures from the Local Plan.

The fifth bullet deals with Public Access, which refers to RDC's online planning
website, and as detailed in response to paragraph 3.11, the website should be
compliant with the planning authority's requirement to maintain a statutory register
of applications under consideration and planning decisions.

Para. 3.14 In light of the requirement to submit all comments in writing (or have them scribed on behalf of the respondent), the second sentence should be reworded as follows:
...Comments need to be made in writing to the Council in the following
ways: ...

Para. 3.17 We are somewhat concerned by the reference that late comments may be
accepted in exceptional circumstances, at the case officer's discretion.Unfortunately, as is often the case, parties that would be interested in a particular
planning application are not always advised of it in the first instance and are reliant
upon been informed by their neighbours or reading about it the local paper. They
should not be denied the opportunity to comment on the application, and we would
suggest that provided that the application is still under consideration by RDC, then
representations should be considered.