Willowbrook Centre response to the consultation on the
draft AMR
The Willowbrook Centre has objected to the draft Annual
Monitoring Report, Section: Consultation and
Equalities.
Our comments relate to:
1. Coverage of topics/issues in the draft AMR;
4. Targets or objectives included in the draft AMR.
Comments
The Willowbrook Centre has objected to the proposed
approach to monitoring consultation and our reasons and
suggestions are as follows:
General objections: There should be a
clearer statement in the Annual Monitor Report as to
whether the council will monitor the Statement of Community
Involvement or any form of consultation, since the latter
might include various surveys not related to the SCI.
Without such statement it would be impossible to keep track
of the effectiveness of the SCI whose main objectives is
not only to guarantee the widest community involvement
possible but also to promote trust and confidence for local
people to engage in planning decisions.
With regards to the AMR proposal to monitor the
proportion of adopted council plans and approved
developments prepared in compliance with the SCI
our objection is as follows:
- Council’s plans, development plan documents and
supplementary planning documents should, in principle,
all comply with the SCI. When they don’t, and
especially in the case of SPD which don’t require a
review by a Planning Inspector, a system of checks and
balances internal to the council should ensure that they
do before they are approved.
- Monitoring the proportion of plans and policy
documents that comply with the SCI is a valuable approach
only if the council is willing to make transparent its
internal system of pre-adoption evaluation.
This will show to the council and to users of the AMR
where and when the process of developing a plan or
planning policy has failed.
- Our suggestion is that the full
process of plan and planning policy preparation including
decisions made by planning committee, council assembly
and executive are reported in the AMR.
With regards to the AMR proposal to monitor the
age, gender, etc. of people involved in
consultation
- the current version of the AMR doesn’t propose
any target and therefore is unable to monitor if
consultation is reaching out to different equalities
target groups in a proportion which is representative of
the borough composition.
- Our suggestion is that monitoring of
the equalities groups should be set against the groups
composition for the whole borough and for the different
borough’s wards of community council’s
areas.
With regards to the AMR proposal to monitor
participants' satisfaction with consultation,
- We object to the use of the word
“satisfaction” because it is ill-defined,
subjective and not explicitly related to the council
performance or to the effectiveness of the SCI and
consultation process.
- Our suggestion is that this aspect
is eliminated from the monitoring of the SCI or embedded
in the fourth aspect (proportion of residents who feel
involved).
With regards to the AMR proposal to monitor the
proportion of residents who "feel involved" using
the Residents Survey, our objection is as follows:
- The Residents Survey results and methods for this
past year should be made available and transparent in
order to allow the users of the AMR to evaluate whether
the Survey is a valuable tool to monitor residents’
feelings about involvement.
- If not already available in the Residents Survey,
specific questions related to the understanding of the
planning and development control process should be
included. These additional questions should avoid
referring to subjective perceptions or feelings of
involvement and produce objective results.