1. What the Statement of Community Involvement is
1.1 This Statement of Community Involvement (SCI) sets out the ways in which partners, stakeholders and the community can be involved in the council’s planning processes.
This covers the production of planning policy and decisions relating to planning applications.
Find our current SCI, adopted in 2015.
2. Why we need to temporarily amend the Statement of Community Involvement
2.1 Due to the COVID-19 pandemic, Brighton & Hove City Council’s Customer Service Centres and some libraries are currently closed or offering reduced services. As such, it's not possible to meet the requirements of the SCI regarding the availability of hard copies of policy documents in public buildings and the council’s libraries.
2.2 National Planning Practice Guidance (PPG) was updated on 13 May 2020 and states that where any of the policies in a SCI cannot be complied with due to current guidance to help combat the spread of COVID-19, the local planning authority is encouraged to undertake an immediate review and update the policies where necessary.
As a result, this addendum sets out temporary changes the council is making to the requirements set out in the adopted SCI whilst COVID-19 restrictions are in place so that plan-making can continue and to reflect changes to the development management process. The addendum should be read alongside the adopted SCI 2015.
3. Temporary changes required which are relevant to planning policy matters
Availability of our documents
3.1 Arrangements set out in the SCI require hard copies of consultation documents to be made available for inspection at the Customer Service Centres (Hove Town Hall, Hove and Bartholemew’s House, Brighton) and libraries. Currently, Customer Service Centres remain closed.
As of October 2020 most libraries in the city have reopened, with the exception of Mile Oak and Hollingbury Old Boat Corner where libraries are in shared buildings. Patcham and Westdene Library, are remaining closed while refurbishment work is undertaken.
The council will make its consultation documents available online through specific consultation pages on the council website.
The council will be able to provide a hard copy of consultation documents for consultees who have difficulty accessing documents online on request. This should be requested by emailing firstname.lastname@example.org or phoning the policy team using the number provided during the consultation period.
For consultations on a pre-submission neighbourhood plan (regulation 14), customers should contact the parish council /forum directly to get a copy of the consultation document.
For consultations on a submission neighbourhood plan (regulation 16), customers should contact the council through email@example.com
When it's safe to do so, documents will be placed in Customer Service Centres and libraries for public inspection. This will be communicated in consultation material. These documents will need to be accessed in a way that follows the council’s wider policies and procedures for ensuring the safety of visitors to the council offices and other relevant premises.
How to respond to consultations
3.2 The council’s preference is that customers respond to consultations online where they can. Paper response forms are accepted but will not be made available in libraries while restrictions relating to the COVID-19 pandemic are still in place.
The council will continue to run consultations online, using the council consultation portal. Responses by email are also accepted.
If customers would like to receive a paper consultation form, they can request one by emailing firstname.lastname@example.org or phone the policy team using the number provided during the consultation period. Forms can then be returned to the council offices in the post.
Consultation periods may be extended where appropriate to provide time for accessing documents and responding.
Meetings, workshops and focus groups
3.3 The council values the views of consultees, residents, interest groups and other stakeholders when developing planning policies.
Due to the government restrictions associated with preventing the spread of COVID-19, the council cannot hold face-to-face meetings, workshops, focus groups or exhibitions. This is to protect the health of our communities and staff.
For consultations, the council recommends that engagement measures recommended within the government’s Planning Practice guidance are used.
These include holding virtual displays, digital consultations and video conferencing to avoid social gatherings. This would be using software like Microsoft Teams and Zoom. If these methods are successful, the council will consider utilising these methods in the future.
Where online software is not suitable or cannot be used by specific groups, the council will use other approaches including phone calls to engage with stakeholders.
Neighbourhood planning and referendums
3.4 The council will continue to support the progression of neighbourhood plans in the city, in a way that aims to help their continued progression. It will do this while following the government requirements for preventing the spread of COVID-19.
There are 2 compulsory consultation stages for neighbourhood plans. The council will continue to advise neighbourhood plan groups on suitable approaches to consultation through their lead officer:
- Regulation 14 consultations need community engagement and encourage feedback and exchange of views with the public - this is done by the Neighbourhood Forum / Parish Council
- Regulation 16 consultations seek views on the final draft plan and are less aimed at engagement - this is done by the local planning authority
3.5 For Regulation 14 consultations, among other mechanisms to support neighbourhood planning, the council will:
- work with the Neighbourhood Forum / Parish Council as the qualifying body to ensure the pre-submission consultation is publicised appropriately including on the Forum/ Parish council website
- work with Neighbourhood Forums/ Parish Council to make sure documents and consultation forms are available to a wide range of interested parties including those who do not have internet access
- advise Neighbourhood Forums/ Parish Council on appropriate methods of engagement considering COVID-19 and its implications for consultation exercises
- advise the Neighbourhood Forum / Parish Council to consider extending consultation periods to provide time for accessing documents and responding, if relevant
3.6 For Regulation 16 consultations among other mechanisms to support neighbourhood planning, the council will:
- publish the consultation and documents online on specific consultation pages on the council website
- allow consultation responses to be sent by email
- facilitate the use of paper consultation forms - you can request paper consultation forms by emailing email@example.com
- allow forms to be returned to the council offices by post
- consider consultation periods being extended, where appropriate, to provide time for accessing documents and responding
3.7 Examinations into submitted neighbourhood plans
The council will continue to support this process.
If physical distancing measures have an impact on parts of the examination, like site visits, the council will work with the examiner and Neighbourhood Plan groups accordingly.
3.8 Neighbourhood plan referendums
These have been postponed until 6 May 2021. This is in line with the Local Government and Police and Crime Commissioner (Coronavirus) (Postponement of Elections and Referendums) (England and Wales) Regulations 2020 which came into force on 7 April 2020.
4. Temporary changes required which are relevant to the Development Management process
Planning performance agreements and pre-application advice
4.1 Our pre-application service is continuing, using online conferencing and email. This will help all applicants continue to get the best advice from the start and go through the application process as quickly as possible during the current pandemic.
Carrying out pre-application meetings on site is considered in conflict with COVID-19 restrictions. This is because it involves meeting people, sometimes in an enclosed space.
Online video conferencing will be used instead of meeting in person. Instead of site visits, we'll ask for photographs from applicants, and use these with aerial photographs and streetview.
4.2 Applicants or developers are expected to consult with the local community before submitting planning applications which are likely to generate public interest.
Such consultations should be accessible and clear to the whole community.
Holding face to face / public meetings could be considered to conflict with COVID-19 restrictions by encouraging large public gatherings.
For pre-application consultations run by applicants or agents, the council recommends using the engagement measures in the government’s Planning Practice Guidance.
These include holding virtual displays, digital consultations and video conferencing in order to avoid social gatherings.
4.3 Due to government guidance on physical distancing, site visits may put officers at risk. Particularly where the inspection of a building needs to be done and/ or an applicant, agent or occupant is on site.
Officers have been asked to have face to face meetings as little as possible. They'll use other methods like:
- conference calls
- online meetings
- photographs provided by the applicant
- aerial photographs/streetview
Non-essential site visits will stop. Essential site visits will be done after completing a risk assessment. Officers have been advised to minimise contact with people on site and go inside buildings as little as possible.
4.4 Councillors are to be physically present to decide applications.
At its meeting on 19 March 2020, the Policy and Resources Committee approved the arrangements that the council is putting in place to continue decision-making.
All planning committee meetings are now held virtually and you can watch the meetings through the webcast.
If you're a member of the public who wants to address the committee about an application being debated, send an email to firstname.lastname@example.org. The committee clerk can arrange for you to either speak to the members over Skype or to have your written statement read out at the meeting.
Visits to sites by Planning Committee members have been restricted to those which are considered essential to make the decision. These visits will need risk assessments to minimise the risk of spreading COVID-19.
Additional committees were scheduled in September to make sure all applications that may be Community Infrastructure Levy (CIL) liable were decided in good time.
All decisions that do not require members’ decision will be made in the normal delegated way.
4.5 The council will continue to place site notices in locations close to proposed developments if it is safe and appropriate to do so.
This approach will continue unless legislation or guidance from government is released which requires the council to use other methods to publicise a site notice.
5. Review of the SCI
5.1 The amendments made to the SCI in this addendum are temporary, to take account of issues associated with the COVID-19 pandemic and the effects this has for community engagement while government restrictions are in place.
5.2 In the event of changes by government to the requirements for preventing the spread of COVID-19, this addendum will be reviewed and either updated or suspended, as appropriate.
If you have any questions on any of the changes in this addendum, please send an email to email@example.com.