How to respond to Pre Application Community Involvement (Pre App CI)?
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Step 1: Developer contacts group
Usually the NPN Administrator will contact your group to let you know that a developer is asking which community group to approach to discuss a development.
Sometimes more that one group will be affected by a proposed development and NPN Administrator will arrange that the other groups are given the same opportunity for involvement.
Step 2: Group representatives
If your planning group is usually run as an open meeting, it is better to appoint a small number of your group to meet with the developer and to report back to the group.
Meetings with a small number of people who have knowledge of the site are more effective than large meetings.
Both sides should treat each other with courtesy. Large meetings can become confrontational and are therefore not a good way of working towards an agreement.
If a number of groups are involved, it is a good idea to appoint one of your number to be lead representative for the whole group, to make sure that the discussion is accurately recorded, to liaise with any other groups involved and to chair any subsequent meetings you may have with the developer.
The different groups may have different responses and not agree with each other’s points.
Ensure that all the points are recorded.
Step 3: Group and developer meet
At the first meeting you should concentrate on finding out what the developer proposes and agree a timetable for further meetings.
Remind the developer that this group is the sole channel for his Community Involvement responsibilities.
Point out that you would like to sign off the Community Involvement Statement (CIS) before it goes to planning.
It is better to avoid expressing opinions directly to the developer at this first meeting before you have had a chance to discuss it within the group and with members of the community most affected by the proposed development.
If a number of community groups are involved on a single development, it is important that they are all at the same meetings to hear the same information and to hear each other's opinions.
You can ask for drawings from the developer to show the rest of your group.
NPN has a list of professionals (architects and planners) who can assist with understanding of developer proposals and drawing up with response free of charge, if needed.
Step 4: How to check that what you are saying is supported by your community
If your group is not composed of those who live immediately around the site, you should check your views with those who do. This might be by circulating a leaflet which lays out your conclusions and asks for their response.
Better still you might offer a meeting with those people to take account of their views.
If the development affects a large number of people you should consider carrying out a short questionnaire poll on a sample basis (guidance on how to do this is available from NPN). You could also draw up a planning statement that sets out the type of development your community agrees is acceptable in the area. This will then be useful for checking your responses to the developer of any site.
The developer may wish to hold public exhibitions or events. It is best to agree the content of the exhibitions and the form of any questions that might be asked beforehand. Exhibitions are not usually an effective form of involvement and cannot be a substitute for the process set out in this guide. However they are a useful way of checking that all the community issues have been identified before the developer makes his Planning Application.
Step 5: Group response to developer and suggestions for s106 contributions
It is good practice to send the developer a written response within 14 days of the first meeting;
tell him what you like about his proposals as well as what you don't like. The aim should be to work towards a mutually agreeable proposal, and to show the developer that community involvement is useful to him, not just another hurdle.
You can express your opinions about anything that you feel is important but remember that the Planning Authority can only take account of issues that are relevant to Town Planning and in particular the current planning policies and any official town plans that cover the site.
At this stage you should start to consider if the development might have an impact that requires changes in the locality, in addition to any changes to the proposals on the site.
You should also consider the order of priority for changes to be made. For example, dealing with additional traffic on the local road system or requiring more community facilities.
It may be possible to make these changes by asking the Planning Authority to get the developer to make a financial contribution to improving local facilities or to carry out additional works beyond the site, through a "Section 106" Legal Agreement (See Supplementary Planning Document SPD4 on the council website for the type of developer contributions that are normally considered)
Step 6: Remember this is a negotiation
Remember and remind the developer, that this is a process of negotiation and that you would welcome further meetings, once he has considered your initial response and that his Community Involvement Statement (CIS) should be signed off by your group representative as an accurate account of the process and what was said.
Step 7: Developer response and revised design
Ask the developer for a further meeting when he can give you his reply to the group's initial response.
This meeting should include a discussion of how each of the points in the response will be handled. Invite the same people to this (and subsequent meetings if they occur) as have already been involved in the first response to make sure there is continuity and that each meeting does not have to go over the same ground.
The outcome should be that you have an understanding of what can be changed to accommodate the group's response and what cannot. This should all be recorded.
Step 8: Record your meetings and discussions
This record can also be offered to the developer to use as the Community Involvement Statement (CIS) to attach to his Planning Application.
If there are any minutes of meetings between you and the developer, make sure that they are accurate since the group or developer may use these minutes as evidence in the CIS .
Step 9: Community Involvement Statement (CIS)
: submitted by the developer with the Planning Application
The Summary page of the NPN
Pre-app Record makes a useful signing-off page which gives the Planning Officer the information he needs to understand the Pre-Application Community Involvement (Pre App CI) process.
The developer can draw up his own Community Involvement Statement (CIS) if he does not wish to use the group's NPN Pre-App record form.
If so, he should send it to the group for them to agree. If the group wishes, it can ask him to him to amend the record before signing it.
If the group or groups can agree the statement, then the lead representative should sign it as a true record.
If you do not agree with the developer's final CIS, tell the Planning Case Officer at the Council. You can send your own Statement, which can be supported by your record form, telling the Planning Officer about the involvement process and the developer's response to your views.
The Planning Officer will use this information in his report to the Planning Committee when it considers and decides upon the Planning Application.
Step 10: Keep the Planning Officer and NPN informed
Copy in all your responses to the Planning Officer and NPN Administrator.
If the planning officer is aware of the community’s views at the earliest stage he can use them to guide him in his responses to developer enquiries.
The NPN will monitor Community Involvement cases in order to improve the process.
January 2010
Some things to remember in Pre App CI discussions
Points to remember
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1 Pre-Application Community Involvement (Pre App CI) is a negotiation.
Work with the developer to achieve the best result for the community.
- 2 Respect the other party and their point of view.
Confrontation is not effective.
- 3 Prepare for the meeting by finding out as much as you can about the
proposed development site.
Contact the Planning Officer and ask to see his Pre-App enquiry response.
- 4 Meetings with fewer people, who have done some preparation, will be more effective than meetings with large numbers of people.
- 5 If more than one community group is involved in the discussions arrange to work together.
- 6 Agree at the beginning of the meeting who are the main contacts and who is recording the discussion.
- 7 Be clear at the beginning of the meeting who you represent and how you are going to feedback to the rest of the community, you or the developer should agree who is going to ensure that the near neighbours are kept informed.
- 8 Agree the timetable for feedback of responses, future discussions and for the programme up to the proposed Planning Application.
- 9 If other Community Involvement techniques, for instance exhibitions and questionnaires, are to be used you should ask to be involved in the content and the format of these events and to see the responses.
- 10 Keep the Planning Officer and the NPN Administrator informed of the discussions.
You could invite the Planning Officer to your meetings.
