The LDF learning and dissemination project is working with ten pilot authorities to capture what they learn from the preparation of their LDF and disseminate that learning to practitioners. The reports of the learning from meetings of the pilot authorities are to be found on the Planning Officers Society and Planning Advisory Service websites.
The pilot authorities met on 1 November 2005, and this bulletin sets out what came out of that meeting. The meeting addressed five areas -
HEALTH WARNING - The material here sets out the broad conclusions which came out of discussion with the pilot authorities, and represents an early view of what seems to be sensible practice. It is not presented as good practice at this time, because the test of that will only come when it has been applied in reality and can be seen to have worked.
Gearing engagement to its purpose at each stage in plan formulation
Stakeholder analysis - A key aspect of engagement is to decide who to engage with. Stakeholder analysis is a simple tool whereby a list is developed at the outset of groups and individuals considered to have a stake in the local area and a particular interest in the LDD being prepared. This can be easily done by a small group of officers and/or members in an hour. The initial list is extended to identify what the area of interest for an individual or group is likely to be. This can be used to consider both who should be engaged on the particular LDD and how to go about doing so.
In considering which approaches to use, there is helpful guidance on the websites of -
There are indications that some authorities have simply carried forward approaches to consultation previously used in local plan and UDP preparation, without questioning whether they are appropriate for the purposes of LDF preparation. It is suggested that some of the approaches developed in community plan preparation and community development will be more appropriate, and that there will be value in discussing the approaches used and their perceived strengths and weaknesses with colleagues working in these areas.
The three stages of engagement - The procedure for preparing an LDF requires engagement with communities and stakeholders at two stages -
In addition, there will be a need for explanation and clarification at submission stage.
Each stage has a distinct purpose, and there needs to be clear thinking to ensure that the approach taken to engagement at each is properly geared to its purpose, and will produce useable findings to inform and influence decision-making.
Issues and options stage - The primary function of this stage of engagement is to establish what are the real planning issues facing the area and the choices which have to be made, so that the options within them can be properly evaluated. In addition to being part of the formal process of DPD preparation this is also a key part of sustainability appraisal, which should ensure that all reasonable options are identified and appraised. In this connection, it should be kept in mind that anyone can ask for any issue or option relevant to the function of the particular DPD to be considered, and that this must then be done unless the matter can be ruled out of consideration because it would take the DPD out of conformity with the adopted core strategy or out of general conformity with the RSS. (Note: an emerging core strategy cannot be used to rule options out of consideration - it can only be used in this way once adopted).
The planning authority should see this stage as having several objectives -
The pilot authorities have had mixed experience of engagement at this stage. There was a common view among the pilot authorities that efforts at the very beginning to raise public interest in the fact that the LDF was to be prepared proved to be of little value. The feeling was that people and organisations want to talk about the issues and how they will be tackled (rather than the process), so it is better to get straight onto discussion of the issues which the plan needs to address.
One authority felt they probably did too much on asking about the issues and that they would benefit from a more focused approach in the future. They had consulted some 1500 community groups and individuals but only received a very limited response, and in future would look to use a smaller database of organisations likely to be interested. Focus groups and workshops were poorly attended, and taking displays to local events to try to stimulate interest had elicited a disappointing level of reaction. They had also consulted via the Council's own newspaper, and found that the open form of the questions made it very difficult to analyse the results. They were reviewing their approaches in the light of this experience.
Barking and Dagenham have worked with voluntary sector umbrella organisations as a means of identifying the particular issues for a range of sectors within the community. There are a number of advantages to be gained from taking this approach : the 'coalface' community sector umbrella organisations have a direct and current relationship with the individual groups hence their contacts and databases are up to date and they have a knowledge of how to interest and reach their constituent groups that is not available to the authority direct. They also run regular events upon which the council can 'piggy back' rather than organising their own resource-intensive event, eg an exhibition stall at a community fair or workshop at a voluntary sector conference. The existing networks thus act as a channel for the council's communications and engagement on the DPD.
Similarly, Doncaster did not have the resources to meet all their Parish Councils individually, so they were arranging meetings with the Parish Associations.
Barking and Dagenham found it helpful to refer to previously gathered information and update it by saying "You told us that........Is this still the case? If not, how have things changed?" Other participants also reported that returning to consultees is a key to obtaining useful responses. Apart from the views obtained, this approach has the virtue of showing that the authority has listened and taken note of what people have had to say. Barking and Dagenham also intend to use focus groups towards the end of this stage to explore the issues raised by the earlier consultation on the issues and options. This will also help to demonstrate continuous engagement. They will pay participants £30 for taking part in a focus group (a practice commonly followed in fields other than planning).
There was a common concern among the pilot authorities about how to balance the need to comply with national and regional policies and targets with local community aspirations, which can be very different. A topical example is housing growth. They had found the need to be absolutely honest about the level of choice actually available, and what the boundaries of a particular consultation are, especially where there is a strong national or regional policy. For example, if the number of dwellings to be provided in a district has been determined by an adopted RSS, it is likely that the main matters of choice will be about where they will go, density, mix and affordability and design. This needs to be made clear at the outset of any consultation. Hillingdon had worked to make sure that stakeholders, councillors and the public understood the requirements of the different tiers of Government policy, and felt this had helped considerably in setting up realistic expectations and facilitated the work on preferred options.
Preferred options stage - At this stage the planning authority has prepared alternative scenarios and identified what it considers to be the best strategy for the area (in the case of the core strategy) or the most appropriate blend of policies or allocations. The purpose of engagement now is to find out how others respond to these ideas before they are worked up into fully detailed proposals. The choices to be made will require a grasp of how different issues and options within them affect each other, so the emphasis should be on approaches which enable explanation and discussion of the implications of different scenarios. This points to use of techniques such as focus groups, workshops, and bilateral meetings with interest groups. The publication of the "Proposals for the DPD" (Regulation 26) and the Sustainability Report at the same time provides the formal opportunity for anyone to make representations, and the authority should ensure that this step provides the means for anyone who is interested in the emerging DPD to have continuing opportunities for involvement as the DPD is worked up for submission. The aim should be to build consensus and develop a sound plan..
The idea of consensus building can be taken forward in two contrasting ways at this stage. In terms of the community as a whole, the planning authority can seek to identify the strategy which enjoys the highest level of general support. This will mean tailoring the approach to engagement to get the views on the main alternative scenarios of the widest possible range of stakeholders and individuals, and not just the "usual suspects". There will of course be disagreement over detail, and the wide and sometimes competing range of interests will mean that there is bound to be some opposition to any scenario, but it is suggested that often there will a considerable level of consensus on the principles of the DPD.
Alternatively, the planning authority can seek to build consensus with its partners and key stakeholders on a strategy which all can subscribe to. This could be done under the umbrella of the local strategic partnership, or by the planning authority bringing the relevant players together. Developing consensus with partners will be valuable both in taking forward spatial thinking about both the issues and the solutions, and in building their commitment to delivery of those aspects of the DPD which fall to them. It will be important to be honest with partners that while the authority is keen to work towards consensus with them it must also listen to other voices, so the eventual preferred options may need to be modified as a result.
Looking at the experience of the pilot authorities, Horsham have used a variety of engagement techniques in relation to their several DPDs. They involved partners in the development of the core strategy, which was linked with a review of the community strategy, and at that stage used the local strategic partnership as the focus of consultation. They found that even though they worked closely together, they would wish to collaborate even more closely next time around.
In relation to their allocations DPD, Horsham worked with action groups, parish councils and others with direct interests in particular sites. They also wrote to householders in properties adjoining sites proposed for development inviting them to a public participation session, and found this significantly increased the number of residents attending sessions and responding to consultation documents. This is a way of reaching people who may not otherwise engage, but they also found that this led to multiple objections which could be repetitious, and it is questionable whether any 'new' views were gained. However, this potential disbenefit should be set against the considerable benefit of gaining significant samples of responses and sound evidence for proposals.
Joint working groups were developed to assist in the development of Area Action Plans, including the PCT and other delivery partners in the area.
The development policies DPD was worked up with individual groups of relevance to the subject and where required, advocates of groups. Horsham officers felt that at this level of policy they really were working together to build consensus on the drafting of policy and that they gained better policies as a result. They found that focussed consultation on specific issues (development control policy issues in their case) does give rise to helpful responses and appears to build some consensus.
Hillingdon chose to consult on preferred options documents containing fully-developed policies, and felt that this made stakeholders, Council members, officers and the public more comfortable with the transition from the UDP to the LDF. They felt that being clear about the detail of the chosen option provided wider scope for prompting early, meaningful responses, and offered more scope to use those responses to improve the policies. Doncaster had also found that consultees wanted documents to be specific, even to including draft policies, and found more general expressions of the intentions of policies too vague and difficult to respond to. Acknowledging that people may want as much clarity over detail as possible, there is of course a risk that they will focus so much on detail that that they do not properly consider their stance on the overall strategy and the relative merits of different scenarios.
Submission stage - It is important to be clear the submission stage is quite different from the deposit stage in the local plan system. The engagement with communities and stakeholders on the content of the DPD should have taken place at preferred options stage, and by the time the authority reaches submission it has made its mind up firmly on the plan it wishes to adopt, and is not consulting on the DPD nor open to any material change in it.
The planning authority will wish to ensure that people and organisations are aware that the plan has been submitted, and that this is the opportunity to make representations, and in particular to raise an objection and have it taken forward for consideration by the Inspector at the examination. It follows that activity at the submission stage will be primarily a matter of explaining the DPD and its policies/proposals clearly, so that people can decide whether to make representations, and do so in an informed manner. This demands honesty and tact from the planning authority. It would be misleading to suggest that the authority is open to significant change in the plan at this stage, or to use approaches which imply that this is the case.
Consideration should be given to how the authority can ensure that all sections of the community are made aware of the proposals in the submitted DPD, and not just from those who may feel threatened by the proposals. This suggests the use of a range of communication techniques.
Authorities need to be clear about the fact that there is no "proposed changes" stage in the new system, and all objections will be forwarded to the Planning Inspectorate for consideration by the Inspector. Occasionally an authority may consider that an objection to, say, the detailed wording of a policy would improve or clarify the document, and be willing to see a change to that effect. The means of dealing with such a situation will be to indicate its willingness for the change to be made in its evidence to the examination.
PPS 12 sets down strict limitations on the changes that can be made after submission, and it would be best to avoid encouraging any late changes, which will require making further opportunities for representations as well as ensuring that SA and community involvement requirements are met.
It should go without saying that consideration should be given long before submission to how representations will be handled, recorded and reported. This will include the development or adoption of a suitable database system. It should also be kept in mind that the Regulations require evidence of the earlier consultations to be reported.
The LDF, the local strategic partnership and community strategy
Building the relationship - When the pilot authorities set out on LDF preparation, there was considerable variation in the extent of their involvement with the local strategic partnership and community plan preparation. At Hambleton and Horsham the planning department was responsible for both the development plan and the community strategy, so the means of integration were readily available, and at New Forest there was established close cooperation. New Forest have now reached the position that there is support in principle from the district Council, LSP and new National Park Authority for the principle of joint working on the LDF core strategy, review of the community strategy and National Park Management Plan. The idea is that there will be a coordinated programme of public involvement and that documents will be produced in an integrated way, with the broad strategy (vision, aims, objectives, spatial strategy and strategic policies) possibly set out in a joint strategy document.
At the other extreme, in some authorities there was little tradition of collaboration or even contact, but things are changing. Hillingdon has seen a big improvement in internal communications and commitment to spatial planning due to powerful champions in the leadership and Chief Executive. The LDF team and the team supporting the local strategic partnership are now working together and pooling knowledge and resources. Close working relationships with the Borough's stakeholders has proved invaluable in developing a preferred options document which will help to deliver a variety of strategies outside the land use planning context, and has gained the support of the local strategic partnership. The ability to show the support of stakeholders has also enabled the case for proposals to be heard by the Greater London Authority where they might have carried less weight if presented by the local authority alone.
The local strategic partnership at Doncaster has become an enthusiastic partner in work on the LDF, and Coventry have similarly maintained good working relations with their LSP. However, another authority has found that under-resourcing of the LSP has limited its capacity to work with the planners, that partnership board members are too busy to see the potential of spatial planning, and any spatial planning sub-groups are not sufficiently influential. Moreover, it should not be assumed that all elected members are enthusiastic about collaboration with the LSP: indeed some are suspicious of what they perceive as giving power or influence to people with no democratic mandate.
Getting the LSP engaged - This leads to the issue of how to get the LSP to engage with the LDF where it is not currently doing so. It is suggested that the answer lies in the experience of Hillingdon and others that powerful champions are needed within the authority, who will both make the LDF a priority and take the message to the LSP that the LDF is important and it really does need to get involved. In this connection, the Planning Advisory Service has commissioned POS Enterprises to develop a communication toolkit to assist planners in "selling" the significance of the LDF to leading members, Chief Executives and Directors, and the senior management of partner organisations.
Some local strategic partnerships may be interested in the LDF in principle, but are so busy with wide-ranging and demanding work programmes that they have real difficulty in giving much time to LDF matters. In such cases it is suggested that agreement should be sought for one of the sub-groups of the LSP to become the vehicle for collaboration with LDF work, or that an additional sub-group should be established. Whichever approach is taken, the sub-group will need to take real ownership and carry significant weight, and include senior representatives of the partners most likely to contribution to delivering the LDF strategy. It should report regularly and substantively back to the main partnership body though a concise report which focuses on the critical issues and seeks explicit endorsement to specific propositions, rather than a progress report to be merely noted.
Some local strategic partnerships are considered to be good at collaboration in service delivery, but not so good at addressing strategic and spatial planning issues. In such cases, the planners need to find ways to help the partners engage in the key strategy choices. At the same time, there is plenty of room for humility here - many planners are having to work hard to change their mind-set from familiar land use planning precepts to an effective grasp of spatial planning and its potential. LSP partners' ways of thinking may be different, but are not fettered in such a way, so interaction with them is a valuable way for planners to open up their thinking to non-land use influences and solutions.. It is suggested that the aim should be wherever possible to work with the LSP partners though informal approaches such as visioning, brainstorming, and consensus building, rather than in the restricting format of formal meetings.
Obstacles to effective collaboration - In developing the working relationship with the local strategic partnership, it needs to be recognised that there are obstacles to integration of the LDF with the community strategy, which will have to be addressed and progressively overcome. They include -
These obstacles are not insuperable, and there are good examples of authorities where effective collaboration is embedded in working arrangements, including some of the pilot authorities. But they do need time, for mutual learning and to build up understanding and trust. Where close collaboration does not already exist, consideration should be given to how to build up relationships and working practices with partners with a view to improving the degree of integration over time. It certainly requires sustained effort, but as Ipswich have found, the fact that the authority and its partners meet regularly and are used to cooperation on matters where agreement is readily reached helps considerably when the time comes to deal with contentious issues.
It will be necessary to be clear and honest with partners about the effects of the statutory system under which the LDF is prepared. There are two aspects to this. First, the LDF will be constrained by Government policy and RSS targets, and partners need to appreciate that there is no point in saying things in the community strategy which cannot be delivered or prevented. They of course are equally bound by higher level policy and direction. Second, the LDF may move away from the community strategy in some manner, whether because the evidence suggests that it should, or the Council feels it must respond to strong public feeling on an issue, or at the end of the process the Inspector may decide that an aspect of a DPD that follows the community strategy is unsound. There therefore needs to be an understanding with partners both that this may happen and that there will then need to be corresponding changes to the community strategy through an early review. There are opportunities in the core strategy to iron out any differences of vision and strategic thinking that will then bind more detailed DPDs.
There is a particular problem for county councils in seeking to collaborate with local strategic partnerships in developing the minerals and waste LDFs, because in many counties there is an LSP for each district council area. Hertfordshire have found that there are considerable differences of functions, organisation and working arrangements among the ten district-based LSPs in the county. This makes it very difficult to engage effectively with them, quite apart from the fact that they have other priorities and may not see a waste LDF as a key issue for them. While it is desirable to persevere and seek opportunities where they can be found to get closer to the district-based LSPs, the practical course is probably to concentrate on working with the county-based LSP, where County Council representatives can champion the need to engage with the LDFs.
Developing scenarios for evaluation
It has become apparent that practitioners are commonly experiencing difficulty in identifying the key choices which the plan needs to make, and bringing them together into alternative scenarios. This appears to be partly due to the fact that current strategy is so familiar that it is difficult to see valid alternatives, and partly because development plan practice over recent years has not generally included formal consideration of alternative scenarios. However, the new system explicitly requires that options are considered and evaluated to come to the preferred options, and of course the appraisal of alternatives is a central feature of strategic environmental assessment and therefore of sustainability appraisal.
The pilot authorities have previously considered the need for challenging options (May 2005) and that material will not be repeated here, rather some brief attention will be given to how valid alternative scenarios might be developed for evaluation.
Since current planning strategy is so familiar to the planning authority, it is suggested that a good starting point is to have brainstorm or workshop sessions with partners and key delivery agencies who of course do not carry any planning policy baggage. Such sessions can use one or more known key issues as starting points, and ask the participants to identify possible solutions. This should bring out possible solutions which differ from current planning strategy in two ways -
While the planners in the sessions might warn that some alternatives present significant difficulties in terms of planning policy, they should not rule out alternatives too early, but allow for ideas to grow and develop. The group can then be asked to identify what they see as the strongest looking possibilities, and also their implications for other matters.
Taking an example which will be relevant to a number of planning authorities, decisions about what ruling densities to adopt will be influential in the scale of urban extension which is needed. So a workshop session could examine the implications of median or higher densities for public transport, traffic, local services, effect on character of residential areas and so on; and similarly consider the impact of the consequent scales of urban extension in terms of both where the development might go and the implications for infrastructure, accessibility and availability of community services, impact on landscape and agriculture and so on. It may be anticipated that as this is worked through it will become clear that other issues are affected, and that some options within them will work better with higher densities or a larger urban extension, and vice versa. Thus alternative scenarios will emerge which differ in a number of ways from each other, and represent genuine sets of choices.
The temptation to evaluate the emerging scenarios should be resisted until there is agreement on their content. Then the planning authority will need to consider their respective merits taking account of a range of factors, some familiar and some relatively new, including -
Annual monitoring reports
The first annual monitoring report is due to be submitted by 31 December. If it shows that reality of LDF preparation is that dates in the LDS were too optimistic, consideration should be given to an early update, before the (anticipated) cut-off date which is expected to be imposed for Planning Delivery Grant. The requirement is to get the AMR to the Government Office by 31 December, but the provision of hard copies for other parties and getting it onto the website can carry over into the early New Year.
The guidance on annual monitoring reports sets out some demanding requirements, which will be difficult to meet in the first year when the necessary information systems are not yet all in place. It is therefore suggested that initial energies should be focused on the areas which are likely to be most sensitive and significant in tracking the delivery of strategy
The ambition should be for the AMR process to include monitoring as part of sustainability appraisal of the emerging suite of DPDs, and to be a shared activity with monitoring of the community strategy by the local strategic partnership. This will assist in bringing the two planning processes together, enable consistent interpretation of the findings., and offer economy in the use of resources. .To be effective monitoring should not merely record what has happened, but review actual progress with the LDF and begin to ask whether policies are being implemented and, more importantly, whether they are achieving their intended purpose. This will become increasingly important as DPDs emerge and make the transition from development to implementation. Moreover, the AMR should monitor the spatial strategy and not just the elements delivered by the planning authority through development control, so input from key delivery partners will be needed. Monitoring needs to be rigorous and genuinely challenging to be effective.
Apart from its other purposes, the AMR should be used internally by the authority as a tool for supporting positive improvement, and not merely to track production of the LDF. The evidence it provides should be essential information for councillors and colleagues, and for not just for planning but for wider authority purposes, such as lobbying and influence.
Getting the foundations right - Two of the pilot authorities have had interesting experiences in establishing the right strategic context for preparing their LDF. Doncaster were unhappy with initial growth figure for the Borough put forward for the regional spatial strategy, which they felt was too low to enable them to address issues successfully. They have worked with sub-regional partners in South Yorkshire to tackle the issue, and this has paid dividends, since they now have agreement on a figure they are happy with which will now be included in the RSS.
Coventry had an internal debate about the appropriate vision for the future of the city and the scale of development associated with it, and its implications relative to the RSS. There is now a common understanding of the context of national and regional strategy, and the potential of the core strategy. While this provides a good corporate foundation to work on, and has as a by-product increased the profile of the LDF, it has caused a delayed start, and the learning from the experience has led to a decision to make the issues and options stage longer than originally planned in order to obtain inclusive preparation and dissemination of the issues. The LDS will therefore need to be revised accordingly.
Reviewing the local development scheme - Coventry expect to review their LDS in the light of the delays they experienced in getting internal accord on the level of growth to aspire to, and other Pilot authorities are also considering a review. In Doncaster's case they feel that in the light of improved understanding of what is involved in DPD preparation that they were optimistic in the LDS, and resources have not arrived to the extent envisaged. Barking and Dagenham have revised milestones to reflect the time taken is sustainability appraisal and to reflect slippage, particularly in relation to SPDs.
New Forest have just managed to achieve the set milestones to date, and find that having them clearly set down in a published programme is definitely an incentive to meet the targets, and is a useful lever in securing contributory work from colleagues and focusing members on decision-making. However, they recognise that there will need to be flexibility in the future, particularly as the new National Park authority is being set up and intended operational relationships with it have to be carried into practice.
Statements of community engagement - Several pilot authorities feel that with hindsight, early drafting of the SCI has been disadvantageous at times, since the early aspirations and ideas on how to go about community engagement have not always proved suitable or beneficial. As thinking has developed and experience and confidence has been gained, it has become apparent that some aspects of the SCI could bind the authority to carrying out activities which they can now see are clearly not cost-effective or worthwhile. This suggests that there is advantage in not preparing the SCI at the outset of the LDF programme, but when there is some experience of what works best which can be reflected in it.
Coventry received considerable support for the pre-submission draft of the SCI, but there was detailed criticism from a small number of local groups which were relatively well-versed in consultation on planning issues more generally. Work with these groups led to agreed changes to the SCI, but this put the planned date of submission back 6 months. They feel it is difficult to assess whether a different approach, possibly with wider community engagement at the beginning, would have had a different outcome.
Working with agents and developers - Getting the local agents who regularly submit applications to engage with the LDD preparation had presented some difficulties. Ipswich wrote to local agents to invite comments on their householder extension guide, but although there had been some complaint about the existing guidance none took up the opportunity. They now plan to try another tack, running a workshop with agents instead.
Horsham found agents prefer to engage through phone conversations, which the agents have identified as their preferred means of contact. They make a written record of the conversation. They got a good take up from an invitation to agents to a session they held on making effective representations, including pointers on how to fill in the relevant tests of soundness on representation forms at submission stage.
Ipswich have found that sometimes the developer will take on the task of consultation. They persuaded a developer to fund a consultation on a green field site through consultants. The consultants found that while there was a large number of objections in the immediate vicinity of the site, these participants nevertheless recognised that the site would be developed and framed their representations accordingly. They found only a small number of objections in the wider community.
Issues in community engagement - Hillingdon have sought to engage with hard to reach groups with limited success. They have come to the view that this is an area where the planning department in isolation can only get so far. Getting to the hard to reach groups needs effective corporate approaches and relationships with outside organisations which the planners can tap into.
Barking and Dagenham are setting up a consultation database which will offer an online consultation tool where each user can register and be kept updated with progress on document preparation and progress generally. Pilot authorities had mixed experience of using web-based approaches, with some reporting it as successful but other disappointed. There was agreement that emails and website materials will not reach some "disadvantaged groups.
Some pilot authorities found the use of the Council newspaper, though heavily promoted from within the authority, of limited value as a tool for consultation, because response levels are low and respondents are self-selecting. Others use it purely to advertise forthcoming consultations and keep residents informed.
Sustainability appraisal - New Forest have worked corporately to prepare a scoping report as a generic document applicable not only to the LDF but also to any Council plan or programme that requires SA or SEA. The aim has been to produce a methodology and assessment criteria that are realistic and practical, and to integrate the criteria, indicators and data sets with those used in the monitoring processes.
Barking and Dagenham have undertaken initial work on deciding the outline content of the core strategy and the process for getting from policy options to preferred options. They carried out a mock exercise (taking affordable housing policy as an example) in which they carried out an initial sustainability appraisal of various policy options, an analysis of (mock) consultation responses and other evidence from plans, policies and strategies. This helped to clarify that it seems more sensible at preferred options stage to generate generic policy approaches rather than specific polices as these are easier to appraise for initial sustainability appraisal. They came to the view that there was little point in devising detailed policies at this stage when the initial sustainability appraisal work can be expected to suggest additional factors or approaches which need to be taken into account in the finalised preferred policy.
They also found it invaluable for the LDF team to work closely with the sustainability appraisal team to ensure understanding of approach, transfer of ideas and continual evolution of policies. The initial SA work raised some important learning points, particularly where it through up a question mark, eg when it said that a particular policy approach could have a positive or negative impact depending on how it was implemented. Such questions were accompanied by valuable suggestions as to how policy approaches could be amended to ensure a positive impact. The point was made that the final output of initial SA work must rest with the SA team to ensure independence.
Hillingdon took the decision to prepare the sustainability appraisal in-house, and feel that although laborious this has paid off for them. They feel it has brought robustness to the overall process of LDF preparation, increased officers expertise, and helped in bringing the preferred options documents for several DPDs together.
One pilot authority's work programme had the report on sustainability appraisal for preferred options stage due to be completed at the same time as the preferred options. This provided no time for the outcomes of sustainability appraisal to be considered in the framing of the preferred options. The issue was overcome, but it does point to the need to design appropriate time into work plans.
Technical studies - Horsham found that some of the evidence from technical studies was only becoming available when they had already prepared preferred options, which could have caused difficulties if the conclusions of the study had been in conflict. This emphasises the need for technical studies and other key research to be front-loaded in the process so that the results are available in good time to be drawn upon in strategy development.
Where consultants are used to provide background documentation which is to be used as part of the evidence base, Horsham make the point to ensure that they submit their reports in a format which can be easily copied and transferred into electronic format for use on the website.
Submission stage - Horsham advise that the number of deposit locations for preferred options documents should be limited: all submission documents, representations received, and a summary of responses have to be provided at each deposit location, which could involve considerable photocopying. With the advice of the Government Office, they are not putting all background documents at each deposit location at submission stage, but will make them available electronically and providing a hard copy executive summary of each.