Effective community engagement in local development planning guidance: impact assessments
These impact assessments have informed the preparation the effective community engagement in local development planning consultation draft guidance. The assessments are being made available for comment in advance of their finalisation and finalisation of the guidance.
8. Partial Islands Community Impact Assessment (ICIA)
8.1. This is a partial assessment as public engagement on the draft guidance and associated impact assessments remains to be undertaken.
Step 1 – Develop a clear understanding of your objectives
8.2. The application and scope of the guidance is set out in Section 4. Whilst applying to all of Scotland, it will be for planning authorities to consider what is appropriate in their local circumstances.
8.3. The guidance will have the strongest link to the National Islands Plan Strategic Objective 10 ‘Empowered Island Communities and Strong Local Partnership’.
Step 2 – Gathering data and identifying stakeholders
8.4. An intensive island proofing exercise was undertaken through a collaborative workshop, held in September 2017 and in advance of publication of the Planning Bill. The results of this workshop are set out below.
8.5. Specific to this consultation, the following primary stakeholders have been identified:
- community councils, development trusts, and other individuals and organisations with an interest in shaping the development of local communities;
- societal groups such as disabled people, children and young people plus Gypsies and Travellers; and
- relevant local authorities.
8.6. Desk top analysis was undertaken of the evidence gathered for the development of the Planning Bill, including the equality impact assessment and ICIA, plus the integrated impact assessment accompanying draft NPF4. Key data from the analysis is set out below.
8.7. The National Plan for Scotland’s Islands was published in December 2019. It noted the following:
- island communities face many different transport challenges when carrying out their daily lives compared to those living in less rural areas of the mainland and urban areas;
- the importance of community was a key theme from the consultation and respondents provided a range of examples that highlighted the uniqueness of the islands and the strengths they provide for cultivating innovative initiatives and projects on a small scale;
- many of the islanders said that they felt remote from where decisions were taken and expressed a desire for more considered decision-making which included them; and
- island communities indicated that although the progress with broadband connectivity was a positive, further advancement was needed given the variation of both mobile and broadband connection between, and within, the islands of Scotland.
8.8. The Planning Bill ICIA was published in June 2019. It noted that:
- there were concerns about the practicalities of getting more people involved in planning, including capacity and the volume of information that community councils already have to deal with;
- the resources available to engage with people was also a concern. Many island communities are already very engaged, but it can still be difficult to involve people at the development plan stage (as opposed to applications);
- greater efforts to involve children and young people could relate well to wider demographic objectives that aim to ensure more people stay on the islands; and
- community trusts could be particularly well placed to provide a long term view.
8.9. Population demographics: National Records of Scotland Mid-Year Population Estimates Scotland, Mid-2020 (2021) indicates that:
- rural and island areas tend to have an older age profile; and
- in mid-2020, islands and mostly rural areas had some of the highest proportions of people aged 65 and over.
8.10. Transport and Travel in Scotland Results from the Scottish Household Survey 2020 Telephone Survey (2022) indicates that:
- a little over half of people surveyed (55%) had travelled the day before their survey interview; and
- fewer people travelled in the oldest age groups, with 45% of those over 70 and just 22% of the over 80s travelling the previous day.
8.11. Settlements data: National Records of Scotland - Population Estimates for Settlements and Localities in Scotland, Mid-2020 (2022) states that:
- Nah Eileanan Siar had the lowest proportion of people living in settlements (29.4%); and
- both Orkney and Shetland are the other areas with the proportion of people living in settlements below 50%.
8.12. The Connected Nations Scotland Report (2019) for internet use notes that:
- island communities have older populations and that internet use is less in older age groups than younger ones; and
- there is a gap between premises in the islands able to access superfast and fibre broadband when compared to premises in other parts of rural Scotland.
8.13. The National Islands Plan Survey Final Report (2021) notes:
- island residents generally perceive that they have little influence over decisions made by local and national organisations, and more influence over community organisations and community councils, particularly in the Outer Isles of Orkney and Shetland, where around half of residents feel they can influence decisions made by their community council; and
- 42% of younger people (aged 18 to 35) compared to 30% of older people (aged 66 and over) report that they can influence decisions made by community organisations such as Development Trusts and community groups.
8.14. Young People and the Highlands and Islands Maximising Opportunities (2018) report notes:
- levels of community participation varied by geography, with the highest levels reported by young people in Orkney (81%), Shetland (72%) and the Outer Hebrides (70%).
8.15. Analysis of responses to Draft NPF4 (2022) notes that:
- around 20 respondents made a comment on the partial ICIA. It was suggested that there needs to be more proactive engagement with island communities about planning;
- respondents highlighted a range of issues that affect island communities, including: housing, childcare provision, lack of stable employment; fragility, and isolation; and
- highlights that it is essential that island people and communities are involved in planning their future development and that this should be reinforced through NPF4 policies to enable island specific issues to be addressed in local development plans and local place plans.
8.16. Local development plan guidance and regulations – ICIA notes:
- 34.5% of responses to the partial assessment were from planning authorities including islands and 10.3% from communities and individuals. Island authorities responding included Comhairle nan Eilean Siar, Shetland Islands, Orkney Islands, and Argyll and Bute;
- matters about Gypsy Travellers;
- more young people feel able to influence decisions made by community organisations than older people (included in Annex B);
- consultation methods are well suited to island communities, including online as well as newspaper promotion of proposed plan engagement, and that ‘Planning Advice Note 3/2010: Community Engagement’ is already in place and includes guidance relating to the needs of minority groups and provision of information in alternative languages which could include Gaelic; and
- concludes that: the provisions offer flexibility for local circumstances including island communities and are not likely to have an impact that is significantly different from the rest of the country; and that the local development plan system will enable tailoring specific to island circumstances / local circumstances, and this is likely to have benefits for Island communities in terms of increased flexibility to tailor plans to local circumstances.
8.17. Potential for differential impacts on island communities of the draft guidance. All of the relevant local authorities (Comhairle nan Eilean Siar, Highland Council, Shetland Islands Council, Orkney Islands Council, Argyll & Bute Council and North Ayrshire Council) are covered by local development plans prepared under the provisions contained in the Town and Country Planning (Scotland) Act 1997. They will be required to have regard to the guidance when preparing their local development plans.
8.18. There is the potential that in locations with more scattered and / or older communities, there may be difficulties in interested members of the public getting involved.
8.19. Given a more scattered and older population and the availability of, and reliance upon, public transport, may mean island populations may be less able to attend events linked to the preparation of a local development plan, or that it is more difficult and costly to do so. However, it is hard to make any conclusion as to the significance of any such challenges compared to other more remote parts of mainland Scotland, where populations may also be more scattered, older and where access to public transport at least may be more difficult compared to larger urban areas.
8.20. The guidance does not intend to address methods of engagement and references Planning Advice Note 3/2010: Community Engagement. However, the Islands Communities Impact Assessment for the local development plans regulations and guidance found the proposed approaches well suited to island communities. The guidance also refers to appropriate engagement techniques, further reinforcing the potential for tailoring to local circumstances of the engagement that is undertaken.
8.21. Notwithstanding this, it is noted that some island communities may not have access to the same levels of internet connectivity as other parts of Scotland or the UK. The Ofcom Connected Nations Scotland Report indicates a gap between premises in the islands able to access superfast and fibre broadband when compared to premises in other parts of rural Scotland. Also, in their response to the ‘Call for Ideas’ on the Scottish Government’s National Planning Framework 4, Orkney Islands Council highlighted poor broadband and mobile phone connectivity speeds.
8.22. Na h-Eileanan Siar and the Orkney Islands have a higher proportion of older people in their population, and older people are less likely or able to travel. The Scottish Household Survey (2020) refers to a clear relationship between age and use of internet, with lower rates of internet use among older adults. In 2019, nearly 100 per cent of adults aged 16 to 24 reported using the internet compared to 43 per cent of those aged 75 and over. This gap is, however, narrowing. More recently, the Scottish Household Survey 2020 telephone survey key findings (2022) also noted that internet use varied with age, with older people less likely to use the internet. 58% of those aged 75 or above and 87% of those aged 60 to 74 used the internet whereas nearly all adults aged under 60 used the internet.
Step 3 – Consultation
8.23. This partial ICIA will form part of a package of assessments accompanying the draft ECEG consultation paper. The consultation paper invites stakeholders to comment on the impact assessments, so including contents, omissions in the evidence, and initial conclusions.
Step 4 – Assessment
8.24. It is likely that island communities would welcome the opportunities provided by the ECEG to shape their local places through engagement on the relevant local development plan. There may be some issues around ability to attend public events, given the specific nature of island communities. But the proposals offer some flexibility for individual circumstances relating to island communities. With the information we have identified at this stage, the significance of these issues, as distinct from those in other remote parts of mainland Scotland, is difficult to gauge. Although it is noted that for the broader regulations and guidance on local development plans, the conclusion was that the approaches were well suited to island communities. The ECEG can be considered as a sub-set of the broader regulations and guidance.
8.25. The ECEG does not prescribe the use of specific engagement techniques, leaving this to local circumstances. Provisions relating to engagement on the participation statement provide communities the opportunity to contribute to the participation statement, and for the local authority to have regard to such views. There remains opportunities for methods such as local media and posters in community spaces to be used as would fit local circumstances. It also leaves open the use of languages such as Gaelic / Scots and community languages as would fit local circumstances.
8.26. Our conclusion at this stage is that there does not seem to be significant implications from the proposed guidance for island communities specifically. However, as the scope of the engagement undertaken to date is relatively small, further engagement on the draft guidance enables views on the initial evidence, framing and assessment to be provided.
ICIA approved by: Simon Bonsall
Position: Senior Planner
Signature: Simon Bonsall
Date Completed: 13 March 2023
ICIA approved by: Tom Arthur MSP
Position: Minister for Public Finance, Planning and Community Wealth
Date Completed: 20 March 2023
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