Thoughts on engagement, consultation, participation...

I've been thinking a lot (even more than usual) about the issue of engagement and consultation in planning, and the barriers that exist to making it meaningful. Fundamentally we have a real issue in how planning, as a system, is set up. I have a much longer half -finished piece on this, but basically it operates on a judicial basis, yet with a statutory requirement for consultation.  It's a bit like saying saying that the general public should be consulted on a complex legal case before it goes to court. 

In this system, consultation is not a decision-making process and, unless your comment/representation is backed up with well-researched evidence, it is likely to be outweighed by the huge amount of professionally produced evidence commissioned by local authorities themselves and by major development interests who submit reams of paperwork. Yet government - in their Planning White Paper - talk about foregrounding consultation. What is this really going to achieve, other than more frustrated lay consultees who find their comments brushed aside, unless consultation is given a different role on the process that affords it real weight? 

I am being devil's advocate here because I know that consultation feedback does influence a lot behind the scenes, and planners often work hard to prioritise it. But there really is a big question here not only for planning but for all public policy making. We need to be clear to our communities about the reasons we consult with them. Is it in order to flush out the areas that might be subject to formal, legal challenge later down the line? Is it user testing, to establish how functional a policy or plan might be? Is it to gather evidence (as per my conversation with Frances Brown the other week)? Is it to influence how the plan is shaped (ie lobbying),  or should there be more direct impacts, akin to the only form of traditional democracy in planning, the neighbourhood plan referendum? And if it has a formal role in decision-making, don't we need to ensure it is undertaken under strict rules and involves a transparently representative cross-section of society, not just the 'usual suspects' - the campaigners with the time and capacity to engage? When a NP goes to referendum and only 10% of the community vote, is that really the holy grail of citizen involvement?

The current statutory requirements for planning consultation are absurdly vague. For plans, it says that authorities should invite basically anyone they thing has an interest in the matter, to tell them what should be in the plan; to publish the plan prior to submission for examination, so that people can comment on it; and to demonstrate how comments - still referred to by the archaic term of representations - have been taken into account. This is similar for most aspects of public policy development, where the Gunning Principles underpin the approach. Gunning's approach is all very well, except that it doesn't say anything about WHY consultation should take place. It assumes that the role and benefits of consultation are self-evident. Given the levels of frustration among those who do engage, and the high proportion of our communities who don't engage at all, this is clearly an incorrect assumption. At the other end, philosophically, we have Sherry Arnstein's well-known ladder of participation. That's still got value too, as a framework to question power structures, but I also have problems with it too. How do you define the citizen who should or can participate; what if there are decisions to be made that are for the wider benefit but locally unpopular (stand up HS2); co-creation works really well for smallish projects but is hard to scale; what does citizen control really mean in practice?

If I was to wave a magic wand, I would look to the judicial system for some solutions here. Why don't we have citizen juries or panels, randomly and representatively selected, as part of plan development? Why don't we ask for citizen input as part of evidence collection - a bit like putting a callout for witnesses through Crimestoppers, or Erin Brokovitch going door to door finding people who had fallen sick - rather than inviting comment on the case file that is eventually brought to court? Going further, why don't we learn from other sectors: shouldn't we do properly funded social research as part of plan development, with a proper ethical framework in place? How can we user test plans to make sure policies are effective in practice? Should we scrap the idea of consultation full stop, and involve citizens in these very different and perhaps more influential ways, where their input is valid, and legitimated, by being undertaken under more scrupulous and rigorous methodologies?

We need to be honest to people about why we are seeking their input, and what part this will play in the process. And until we get procedural clarity on what government and PINS actually think consultation is for, and how much weight it should be given - we will continue to struggle to direct resources into really good local engagement - and to bring our communities along with us. Over to you, Robert Jenrick.