Introduction
Are you responding as an individual or an organisation?
Please select one item
(Required)
Radio button:
Unticked
Individual
Radio button:
Ticked
Organisation
What is your name or your organisation's name?
Name/orgname
(Required)
Nairn Residents Concern group
The Scottish Government would like your permission to publish your consultation response. Please indicate your publishing preference:
Please select one item
(Required)
Radio button:
Ticked
Publish response with name
Radio button:
Unticked
Publish response only (anonymous)
Radio button:
Unticked
Do not publish response
Page One
1. The guidance identifies a series of principles for effective community planning. Do you agree with them? Should there be any others?
Please explain why:
The Nairn Residents Concern Group (NRCG) support the principles and the spirit of the Community Empowerment legislation. However, there would appear to be crucially important areas, such as accountability, engagement, breadth of remit, development planning, budgeting which need to be strengthened quite considerably.
Accountability - Albeit that the legislation stresses over and over again that CPPs are accountable to communities for gathering, preparation, production, progress and outcome of locality plans there appears to be a different slant being taken at Highland Council, where it has been decided that accountability will be vested in the Community Planning Board/Chief Officers Group and not truly with the Communities. See Paper attached (refer to appendix 1). This is a matter of concern and does not comply with the spirit of the Act; the Scottish Government was clear; there should be bottom-up decision making at local level to reflect the desires, wishes and visions of local communities. -
Engagement - Engagement/consultation/participation between CPP Board/Chief Officers Group and the community of Nairn has been non-existent. Apart from one or two residents who are actively interested in Community Empowerment, Community Planning etc. 99.9% of Nairn residents have never heard of the CPP Board and what it is supposed to do; residents could not even hazard a guess at what is contained in the present SOA. No group in the Town was ever engaged or consulted in the process.
As an example of what the community thinks about engagement with Highland Council, many residents have been involved in development plan consultations and planning applications and spent hours/days preparing comments/objections, only to realise that their comments have been disregarded, and not listened. The object of the exercise was to tick a box.
Community Planning engagement MUST be more than a tokenistic engagement. Realistic ideas, visions and expectations of the community must form the basis of community planning and must be all inclusive. There should be no attempt to minimise the importance of community engagement by imposing a restrictive remit, or only inviting comments on suggestions made by Chief Officers.
The Nairnshire Area Committee will disseminate information to its community to ensure that it is kept informed and engaged.
Breadth of Remit – The Core Remit of CPPs within the Highland Council area has been agreed as –
• Developing Local Plans for Children and Adults – statutory
• Develop Local Improvement Plans/CLD plans focusing on communities facing the greatest level of inequality as a result of socio-economic disadvantage – statutory
• Identify local actions and priorities.
As can be seen from the above, the remit is narrow and restrictive and CPPs will only be allowed to operate within this prescriptive environment. There is no specificity about health, social care, education etc. This handcuffs the Community from taking a wider perspective and vision of what is required for their Community and is detrimental to joined up and integrated community/development planning.
Why Chief Officers are not recommending such an integrated system is unfathomable. Could it simply be a case of Chief Officers protecting/strengthening their empires by dictating what Communities can and cannot do instead of facilitating and encouraging Communities to take responsibility for developing their towns.
Development Planning – As can be seen from Breadth of Remit above, development planning is certainly not an area where the Communities are permitted to proactively participate, in fact when this question has been raised specifically with Highland Council, a quick, firm rebuttal was forthcoming. However, in order to develop and understand local needs, circumstances and aspirations for community planning and pull these together into a LOIP, Communities need to be able to envision their own development plan requirements, i.e. identify what these are, where they are, when the community is able to sustain development and what type of developments are right for their community. The Community also needs to identify with local transport, housing and infrastructure strategies. (See para 78 of draft guidelines).
Empowering Planning to deliver great places Report (May 2016) –
• reinforces the importance of planning and development plans as a central and powerful driver of the place agenda (Rec. 1) (as the essence of Community Planning)
• a statutory duty for development plans to be aligned with community planning requires statutory weight (Rec. 9);
• communities should be empowered to bring forward their own local place plans, and these should form part of the development plan (Rec. 44)
• a working group should be established to identify barriers to greater involvement in planning taking account of measures contained in the Community Empowerment Act and the Land Reform Act (Rec. 47)
Budgeting – While Communities are being encouraged to develop plans for children and adults etc. there is no mention of associated budgets. No one can see into the future, but in order to achieve realistic, timely and cost-effective planning with deliverable outcomes, Communities need to have control of budgets which directly impact on their communities. Not having ownership of such budgets, makes a nonsense of the whole process and encourages unachievable deliverables because there is no tangible responsibility for costs.
Accountability - Albeit that the legislation stresses over and over again that CPPs are accountable to communities for gathering, preparation, production, progress and outcome of locality plans there appears to be a different slant being taken at Highland Council, where it has been decided that accountability will be vested in the Community Planning Board/Chief Officers Group and not truly with the Communities. See Paper attached (refer to appendix 1). This is a matter of concern and does not comply with the spirit of the Act; the Scottish Government was clear; there should be bottom-up decision making at local level to reflect the desires, wishes and visions of local communities. -
Engagement - Engagement/consultation/participation between CPP Board/Chief Officers Group and the community of Nairn has been non-existent. Apart from one or two residents who are actively interested in Community Empowerment, Community Planning etc. 99.9% of Nairn residents have never heard of the CPP Board and what it is supposed to do; residents could not even hazard a guess at what is contained in the present SOA. No group in the Town was ever engaged or consulted in the process.
As an example of what the community thinks about engagement with Highland Council, many residents have been involved in development plan consultations and planning applications and spent hours/days preparing comments/objections, only to realise that their comments have been disregarded, and not listened. The object of the exercise was to tick a box.
Community Planning engagement MUST be more than a tokenistic engagement. Realistic ideas, visions and expectations of the community must form the basis of community planning and must be all inclusive. There should be no attempt to minimise the importance of community engagement by imposing a restrictive remit, or only inviting comments on suggestions made by Chief Officers.
The Nairnshire Area Committee will disseminate information to its community to ensure that it is kept informed and engaged.
Breadth of Remit – The Core Remit of CPPs within the Highland Council area has been agreed as –
• Developing Local Plans for Children and Adults – statutory
• Develop Local Improvement Plans/CLD plans focusing on communities facing the greatest level of inequality as a result of socio-economic disadvantage – statutory
• Identify local actions and priorities.
As can be seen from the above, the remit is narrow and restrictive and CPPs will only be allowed to operate within this prescriptive environment. There is no specificity about health, social care, education etc. This handcuffs the Community from taking a wider perspective and vision of what is required for their Community and is detrimental to joined up and integrated community/development planning.
Why Chief Officers are not recommending such an integrated system is unfathomable. Could it simply be a case of Chief Officers protecting/strengthening their empires by dictating what Communities can and cannot do instead of facilitating and encouraging Communities to take responsibility for developing their towns.
Development Planning – As can be seen from Breadth of Remit above, development planning is certainly not an area where the Communities are permitted to proactively participate, in fact when this question has been raised specifically with Highland Council, a quick, firm rebuttal was forthcoming. However, in order to develop and understand local needs, circumstances and aspirations for community planning and pull these together into a LOIP, Communities need to be able to envision their own development plan requirements, i.e. identify what these are, where they are, when the community is able to sustain development and what type of developments are right for their community. The Community also needs to identify with local transport, housing and infrastructure strategies. (See para 78 of draft guidelines).
Empowering Planning to deliver great places Report (May 2016) –
• reinforces the importance of planning and development plans as a central and powerful driver of the place agenda (Rec. 1) (as the essence of Community Planning)
• a statutory duty for development plans to be aligned with community planning requires statutory weight (Rec. 9);
• communities should be empowered to bring forward their own local place plans, and these should form part of the development plan (Rec. 44)
• a working group should be established to identify barriers to greater involvement in planning taking account of measures contained in the Community Empowerment Act and the Land Reform Act (Rec. 47)
Budgeting – While Communities are being encouraged to develop plans for children and adults etc. there is no mention of associated budgets. No one can see into the future, but in order to achieve realistic, timely and cost-effective planning with deliverable outcomes, Communities need to have control of budgets which directly impact on their communities. Not having ownership of such budgets, makes a nonsense of the whole process and encourages unachievable deliverables because there is no tangible responsibility for costs.
2. The draft guidance sets out common long-term performance expectations for all CPPs and community planning partners. Each CPP will adopt its own approach towards meeting these expectations, reflecting local conditions and priorities. Even so, do you think there are common short- or medium-term performance expectations which every CPP and partner should be expected to meet? If so, what are they?
Please explain why:
While it is acceptable that all performance expectations should be agreed locally by individual partnerships and their Communities, the NRCG consider it important that there are common short/medium term performance expectations which every CPP and partner should be expected to meet. Some communities may require a more frequent update, particularly where there are urgent priorities.
3. The 2015 Act requires CPPs to keep under review the question of whether it is making progress in the achievement of each local outcome in their LOIP and locality plan(s). CPPs must from time to time review their LOIP and locality plan(s) under review, and to revise them where appropriate. Even with this, do you think the statutory guidance should require CPPs to review and if necessary revise their plans after a specific period of time in every case?
Please select one item
Radio button:
Unticked
Yes
Radio button:
Ticked
No
Please explain why
Individual CPPs should be required to agree, with their Community, a timetable for when they propose to review their LOIP and locality plan. Dependent on the complex/urgent nature of some plans, reviews may be required more frequently than others.
4. What should the statutory guidance state as the latest date by which CPPs must publish progress reports on their local outcomes improvement plans and locality plans?
Please select one item
Radio button:
Unticked
4 months
Radio button:
Ticked
6 months
Radio button:
Unticked
Other
If other, please provide timescale and please explain why:
Although six months is a reasonable period to allow sufficient progress, it may be that local CPPs will require an earlier progress report. However, this should be left to individual CPPs and their Communities to determine.
5. Do you have any other comments about the draft Guidance?
Do you have any other comments about the draft Guidance?
Not as such. The comments set down at Q.1 broadly cover the areas of concern for the NRCG.
The Group would, however, stress the importance of each CPP’s individuality and uniqueness to the community it represents. Thus there should be no pressure on CPPs to conform to a Highland-wide criterion. CPPs are accountable to their Communities in the first instance; other lines of accountability must come second.
The Group would, however, stress the importance of each CPP’s individuality and uniqueness to the community it represents. Thus there should be no pressure on CPPs to conform to a Highland-wide criterion. CPPs are accountable to their Communities in the first instance; other lines of accountability must come second.
6. We propose that the draft regulation for locality planning should set one criterion only, which is a maximum population permissible for a locality. Do you agree?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
What are your reasons?
The cap in the draft regulation is appropriate.
7. The draft regulation sets a maximum population size for localities subject to locality planning of 30,000 residents. It also proposes an exception which allows a CPP to designate a local authority electoral ward as a locality even where its population exceeds 30,000 residents.
Are there circumstances in which these criteria would prevent a CPP from applying a reasonable approach to locality planning?
The NRCG has no comment to offer on this question as a Nairnshire CPP would fall within the locality planning of 30,000 residents.
8. Do you have any other comments about the draft Regulation?
Do you have any other comments about the draft Regulation?
If the October 2017 deadline is to be met for the finalisation and signing off of a Nairnshire CPP LOIP/Locality Plan, it will be important to commence the process as soon as possible. Setting up the CPP as an entity, embracing all partners and community organisations, gathering information, ideas, aspirations, development plans, and setting out the specific local criteria which will be applicable to the Nairnshire CPP, will take many months to get off the ground.
Our community is already involved in a major development re-appraisal which has wide repercussions for the area as a whole, together with other serious infrastructure concerns. These issues impact significantly on community planning within Nairn and therefore there is a need to recognise that such issues cannot be considered in isolation nor exempted from the overview of community/locality planning. Perhaps a moratorium needs to be put in place with regard to major developments until the Nairnshire CPP has the opportunity to apprise itself of all local circumstances and aspirations, which could then inform other plans which include major developments, local transport strategies etc.
Our community is already involved in a major development re-appraisal which has wide repercussions for the area as a whole, together with other serious infrastructure concerns. These issues impact significantly on community planning within Nairn and therefore there is a need to recognise that such issues cannot be considered in isolation nor exempted from the overview of community/locality planning. Perhaps a moratorium needs to be put in place with regard to major developments until the Nairnshire CPP has the opportunity to apprise itself of all local circumstances and aspirations, which could then inform other plans which include major developments, local transport strategies etc.
9. Are there any equality issues we should be aware of in respect of local outcomes improvement plans and locality plans?
Are there any equality issues we should be aware of in respect of local outcomes improvement plans and locality plans?
It is important to ensure that CPP resources are focused on supporting as broad an engagement catchment as possible. However, engagement from whatever quarter of the community, should be encouraged and not derided or indeed set aside, because it is seen as not representative. The fact that members of the community wish to be engaged, on a voluntary basis for the benefit of the community, should be seen a positive step towards encouraging others to participate in the future.