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Community Involvement

Comments on the Statement of Community Involvement of Leeds Local Development Framework
Draft for Consultation, November 2005

1. Leeds HMO Lobby is an association of local community associations, campaigning for action on concentrations of HMOs, especially in & around Headingley. Since this is primarily a planning issue, the Lobby is very interested in community involvement in the planning process. The Lobby has already responded to the Early Draft for Consultation (June 2005). The Lobby welcomes a second opportunity to contribute to the development of a Statement of Community Involvement for Leeds, and has again four main observations to make [these refer to the Comment Form, as indicated].

2. Appendix 3 of the Draft concerns ‘Community & Stakeholder Groups in Leeds’. The third section mainly comprises a list of Interest Groups, that is, ‘Groups which represent the interests of ...’ (and the list includes disadvantaged, health, recreation, transport, women’s groups, and so on). But the Appendix makes no mention of local community associations, by which we mean associations which represent the concerns of a community in a specific geographical locality (like the member organisations of Leeds HMO Lobby, such as South Headingley Community Association, North Hyde Park Neighbourhood Association, Far Headingley Village Society, etc.). In fact, we would argue that Local Community Associations are of greater significance in this context than Interest Groups, for two reasons. First, being locality-based, Local Community Associations are far more likely to take an interest in planning matters than are Interest Groups. This is not to say that the latter are not on occasion interested, or should not be consulted. But planning is about land-use, and Local Community Associations (by definition) are concerned with the uses made of the land-area they represent – in short, with spatial issues. Secondly, it is clear from the final section of Appendix 3 (and throughout the Draft) that the Statement of Community Involvement aims to be inclusive. In this respect, Interest Groups are by definition exclusive, the concern of each (quite properly) is with the interests of a specific group, and not with those of other interest groups (other ethnicity, faith, occupation, recreation, etc). On the other hand, each Local Community Association aims to be inclusive, and to represent the interest of everyone in their locality (regardless of ethnicity, faith, and so on). In its previous response, the Lobby drew attention to these Associations, but they remain ignored by the new Draft. Therefore, Leeds HMO Lobby recommends (again) that Local Community Associations should feature prominently in any list of candidates for community involvement. [Questions 4 and 8 of the Comment Form.]

3. Appendixes 4 and 5 of the Draft are concerned with the preparation process for ‘Development Plan Documents’ and ‘Supplementary Planning Documents’, including Consultation Stages. The latter comprises three stages, and the former comprises four stages. We have just been through the Leeds UDP Review, including Outline Proposals, the First Deposit, the Second Deposit, the Public Inquiry – and we are not be finished yet. One thing is clear: participation in such a process requires enormous stamina. This is not a problem for professionals (in the public or private sector). But it is an issue for community groups, like Local Community Associations. All this consultation work is done in their own time, in their own homes, at their own expense. There is a limit to the resources (the stamina) they have available. Attenuated stages of consultation are in fact a deterrent to community involvement. In its previous response, the Lobby drew attention to the resource implications for the community of the consultation processes: but this issue remains ignored by the new Draft. Therefore, Leeds HMO Lobby recommends (again) that the procedures for community involvement take account of the resource implications for the community. [Question 5 of the Comment Form.]

4. It is not only stamina which Local Community Associations and other community groups may lack. The professionals also benefit from expertise. Lack of expertise puts community representatives at a distinct disadvantage. The community needs expert advocates. In Leeds, the Inner NW Area Committee has addressed this problem by employing its own Community Planning Officer. This officer’s duties include advising groups in the Area (especially Local Community Associations) on planning matters – legislation, policy, development control, enforcement, and so on. Their experience has proved invaluable. Other Areas might make similar full- or part-time appointments for the same purposes. This point was made in the Lobby's previous response. Reference to such expert support might be made in Appendix 2 of the Draft, which concerns 'Consultation & Participation Methods'. Therefore, Leeds HMO Lobby recommends (again) that community involvement should be facilitated by support from expert advocates (like Community Planning Officers). [Question 5 of the Comment Form.]

5. Appendix 4 and Appendix 5 outline the preparation process for ‘Development Plan Documents’ and ‘Supplementary Planning Documents’, and Section 4 explains what these Documents are. In neither part of the Early Draft is there any indication that SPDs certainly (and DPDs possibly) might be initiated by the community. In Inner NW Leeds for instance the community (in the form of Far Headingley Village Society) has already produced the Far Headingley Design Statement – which has been accorded Supplementary Planning Guidance status (SPG26). And a coalition of Local Community Associations plans a companion Design Statement for Headingley, with the intention that it should be a SPD. Meanwhile, the Lobby has also put forward a proposal for an Area Action Plan for Inner NW Leeds. The community could hardly be more involved in the planning process than in taking such initiatives. The Lobby is pleased to see an allusion to this possibility at the foot of page 24, in Appendix 1. However, if community involvement is to be encouraged, the Lobby believes that this possibility could be given a higher profile in Section 4 and in Appendixes 4 and 5. Therefore, Leeds HMO Lobby recommends that the Statement of Community Involvement draw attention more prominently to the possibility of community involvement in the very initiation of planning documents. [Question 5 of the Comment Form.]

6. Leeds HMO Lobby and its member organisations look forward to representing the community in its involvement in the preparation of Leeds Development Framework, including for instance the Core Strategy, Area Action Plans (such as the City Centre) and SPDs, both for areas (especially Inner NW Leeds) and for issues (especially housing). [Question 9 of the Comment Form.]

July 2005, revised December 2005

Leeds City Council's Statement of Community Involvement was formally adopted on 21 February 2007.


Leeds HMO Lobby
email: hmolobby@hotmail.com website: www.hmolobby.org.uk/leeds