CovSoc’s Response to the Draft SCI

Dear Councillors

The Response of the Coventry Society to the Draft Statement of Community Involvement

Thank you for consulting us on the proposed new Statement of Community Involvement.

The Coventry Society is the civic amenity society for the city of Coventry and has been in existence for fifty one years. We are a registered charity and we campaign to conserve the city’s heritage and improve the quality of development and the environment in the city. The Society works to encourage all Coventry’s citizens to have a say on the future of our city. We are part of a wider civic movement and our umbrella organisation, Civic Voice, is also responding to this consultation.

Coventry has a long tradition of community engagement in planning. Donald Gibson established a civic showcase in Civic Centre II where models of the proposed city centre were put on display and citizens were invited in to discuss the plans with the planners and architects.

More recently Area Co-ordination and then Neighbourhood Management were created to engage with the city’s communities about the functioning of the City Council and other public services.  Ward Forums provided a readily available consultation mechanism for planning and other matters.

Up to the last decade, the Council would regularly organise Design Forums for all significant planning applications where the public could hear from developers and put questions to them directly. The principle was that such forums should be held early in the design process where changes to plans can easily be made. Perhaps now is the time for their re-introduction, perhaps in an online or hybrid form.

The Jerde Plan for the city centre in the 2010s had extensive engagement in the city. John McGuigan, the Director of City Development personally attended every Ward Forum and gave a presentation about the project and listened to people’s views. Whilst we hated the plan, the Society gives full credit to the City Council for the extensive engagement with the city’s communities on it.

In view of this fine history, the Society is disappointed at the lack of ambition of the draft SCI. Whilst we acknowledge that the SCI meets the minimum statutory standards we had hoped for much more.

The SCI continues the current low level of engagement between the planning service and the people of the city, exemplified by the almost complete lack of public engagement with the current City Centre South development. This plan, which will have a significant impact on the city centre lasting a generation, has had the absolute minimum of public engagement, limited only to a couple of online sessions led by the developer.

At present most City Council consultation, including this consultation on the SCI, is focused through the Let’s Talk Coventry website.  We value this comprehensive online approach to consultation. However there are issues that need to be addressed. As it is necessary to register with the website, this inevitably limits the audience to any consultation and tends to result in a small clique of interested residents who respond to a range of consultations. We would recommend that with planning consultations it should be possible to respond to a consultation without having to register and login.

Detailed Observations

• The Planning System is a very complicated and constrained process, which is difficult for a lay person to comprehend. The local planning authority is often blamed by residents for approving planning applications where it had no alternative but to do so because of national policy or other considerations. Council planning officers are the experts about how things work, whilst residents are generally ill informed about such matters. Such power imbalance does not lend itself to effective engagement. For consultation to be effective there is a need to empower residents by educating them about the planning world, so that they can focus on areas where there is a chance of achieving change. What is needed is a programme of training and support for community organisations so that they can become true participants in decision making rather than unhappy observers and complainants.
• The SCI mostly conceives ‘community’ to mean geographical communities. But there are many other types of community in the city that have an interest in its development and many of those communities are organised and represented through a host of voluntary and community organisations. Their role should also be recognised.
• We would like to see proposals included to consult with ‘hard to reach’ groups. Such groups might include disadvantaged communities, people whose first language is not English, young people and people with limited access to the Internet.
• We would like to see the re-establishment of Ward Forums, but if that is not possible then a new online pattern of ward pages, focused around the ward councillors. Details of planning applications within each ward could be showcased there together with the local impact of council policies.
• With the Coventry Local Plan being reviewed in 2022, we would like to see early and deep engagement with the people of the city in this updated document.  The re-establishment of ward forums should be part of the consultation processes on the development of the Plan.
• We would like the SCI to include proposals for the promotion, support and encouragement for people to submit applications for local listing and reporting issues relating to Conservation Areas or other heritage assets. We would specifically like to read of action to engage local communities in the preparation of Conservation Area Assessments and Management Plans.
• We would like the SCI to include a list of statutory consultees, local group categories and duty to cooperate bodies, perhaps as an appendix. This would be helpful in demonstrating to the public the types of bodies councils consult as part of the statutory process.
• Although the draft SCI includes reference to the use of digital consultation, we would like to see a section of the document dedicated to this and being more pro-active and forward looking, rather than just responding to the Covid crisis.
• We would like to see a stronger emphasis on pre-application engagement with local communities on significant developments. We would like to see the local authority make it clear to developers that this is a requirement of the process and not just something desirable.
• The City Council includes a list of all planning applications on its website. However the information provided is so broad and extensive that it is not easy for a community group (or individual) to see what is happening that is significant or important, amidst a plethora of applications for extensions and lawful development certificates etc. Whilst an extension might be important to a neighbour, it is not generally significant to the wider city. The Coventry Society provides a service of filtering planning applications every week and re-listing the more significant applications in a more accessible format on our website at https://www.coventrysociety.org.uk/planning-applications.html  Over recent months we have also highlighted the most interesting applications. We think that the Council should take over this responsibility and provide alternative filtering of applications to make the weekly lists more relevant to people in the city. For example we think that it should be possible, at the click of a link, to see all applications in a Ward; all applications in Conservation Areas, all applications for Listed Building Consent, all Outline applications etc. We think that the SCI should include a commitment to developing such an approach.
• We would like to see community engagement in the process of identifying the necessary amelioration associated with major developments. Currently section 106 contributions are used as a milch cow for the education and health services and local residents who have to put up with the damage to their environment caused by development get no say in how it’s spent.  We would also like to see community engagement in the development of policy in this area and especially if the council makes the much delayed move toward the use of a Community Infrastructure Levy.
• We are aware that engagement with the public is a scary thing for some officers. We would like to see a training and support programme put into place to assist officers engaging with the public. We believe that done properly engagement can be a fulfilling experience for officers.
• With the Government giving much greater emphasis than previously to the quality of new design, especially in housing, we would like the SCI to include proposals about how that will be achieved in Coventry. It is clear to us that local communities need to be involved in the development of design guides and statements.  
• We acknowledge that engagement requires resources and that the City Council is limited in the resources available to them. However we feel that as a minimum the Council should appoint a Planning Engagement Officer to promote, support and develop the engagement process in the city. 

Research carried out on behalf of Civic Voice has demonstrated appallingly low levels of trust in local authorities on planning matters. In research undertaken nationally people were asked whether they trusted their local council to make decisions on large-scale development in the best interests of their local area. Just 7% of respondents said they did. Whilst we have no comparable data for Coventry, we believe that the situation is much the same. The SCI is therefore a key first step in changing the way that the Council works with the local community and gives the opportunity to work towards a change in the way the Council works with the City’s residents, local communities and interest groups and the perception of the council.

We believe that consultation and engagement should be an ongoing process and in this spirit the Society would be happy to continue to be engaged in the development of enhanced engagement between the City Council and Coventry residents.