I have recently moved within Iceni Projects from Edinburgh to join the London Planning team. On a personal level, this has been a significant change for me – the first time I’ve lived permanently outside of Scotland and having to get used to everything this entails: the positives including a busy office and all the things London has to offer; and the negatives such as supermarkets closing early on Sundays and questionable tap water.
Professionally, there has also been a significant change. Setting aside obvious variations in Scottish and English planning terminology and legislation, one of the clearer changes has been the absence of statutory pre-application engagement for major development proposals.
In Scotland, statutory pre-application consultation forms part of the pre-application process for every Major and National development. This will include a minimum of two in-person pre-application consultation (PAC) events where the local community and other stakeholders are invited to view the proposals and share thoughts. The Applicant is then required to produce a record of all public consultation activities including a summary of feedback received and an overview of how this has been considered within the application, known as a PAC report.
A similar process is followed in Wales, where my new planning, EIA, Futures, Economic and engagement team members just last week supported a client in securing resolution to grant planning permission for the 17-acre Cardiff East Park and Ride scheme.
In England, whilst there is no statutory engagement during the pre-application stage, most LPAs now expect some form of engagement to accompany large-scale or sensitive applications. Local authorities will set out some of the approaches available to prospective applicants in their Statement of Community Involvement (SCI) and the approach can often be discussed with Planning Officers during pre-app meetings. The Applicant will then submit a SCI to accompany the final planning application.
Southwark Council has gone one step further though, adopting a new SCI in December 2022 which introduced the requirement for an engagement strategy to be submitted at the pre-application meeting.
The absence of set protocols for engagement would appear to increase the need for a bespoke engagement consultant to assist with development proposals, as the approach required will be different for every project.
From discussions with my new Iceni Engagement colleagues, it appears that despite the differences between the two systems, the overall quality of engagement will largely depend on the approach taken by the prospective applicant, and the regard in which they hold the overall engagement process. In Scotland, attendance levels at PAC events could also be impacted by how active the local Community Council is on their social media forums.
Through my experience at Iceni, I understand the value that can be added to a project through constructive, early engagement. It can allow the project team to gather feedback and answer questions about the proposed development, addressing ideas and concerns from the outset. Most significantly, a meaningful level of engagement can result in significant changes being made to any scheme, prior to the application’s formal submission.
At Iceni, we have a strong engagement team who will be able to assist with any enquiries on pre-application engagement. North of the border, our planning team have extensive experience of organising the statutory events and will normally recommend additional measures which can be taken to increase the level of early engagement for any project.