Draft Delivery Agreement (March 2023)

Part 3: The Community Involvement Scheme

3.1. Overview

3.1.1. Part Three sets out how the Council proposes to engage with stakeholders and the community in the preparation of the RLDP. It is essential that the right people are involved at the right time to build consensus and ensure early and effective stakeholder engagement to shape the spatial strategy, policies and proposals of the plan.

3.1.2. The LDP Regulations require the Council to work in partnership with a range of stakeholders in preparing the RLDP including the general public and Specific and General Consultation bodies (see Appendix 3). Table 2 sets out the key consultation periods with further detail of engagement at each stage contained in the detailed CIS in Appendix 4, which sets out who will be formally involved in the RLDP process and how and when the participation and consultation will occur. Similarly, the previous CIS has been reviewed in terms of lessons learned to inform the current scheme. This is set out in Appendix 5.

3.2. Key Principles for Engagement

3.2.1. The Swansea Corporate Plan 'Delivering a Successful and Sustainable Swansea' (2022-23) demonstrates the Council's emphasis on effective engagement with communities and stakeholders in the work the Council undertakes.

3.2.2. The Draft Consultation and Engagement Strategy 2022 seeks to ensure effective consultation and engagement with residents and partner organisations to improve the access, quality and delivery of its services and the decisions it takes. The draft strategy sets out the Councils approach to assist in engaging with residents and service users and identifies the key principles for delivery in respect of consultation and engagement in Swansea.

3.2.3. The key guiding principles of delivery in the Consultation and Engagement Strategy around 'Planning', 'Doing' and 'Decision Making, Review and Feedback' have informed the CIS and will inform the detailed engagement plans for each stage of the RLDP process. These principals were developed using The National principles for Public Engagement in Wales and the National Children and Young Peoples participation standards for Wales. The strategy also supports the Council in meeting its duty under the WBFGA and the Equality Act. In developing the detailed consultation arrangements at subsequent stages, the team will consult with the Councils Engagement Officer to ensure effective engagement. Ultimately any consultation on the RLDP will need to adhere to the four Gunning principles:

• Consultation should take place at a 'formative stage' - In practice this means that the decision should not already have been taken
• Consultation should include sufficient information – In order that consultees can give the matter intelligent consideration
• Adequate time needs to be provided for consideration and response – In practice this means that consultees must be given enough opportunity to take part in the consultation in the time allowed
• Consideration of consultation responses – We need to be able to demonstrate how the consultation responses have been considered within the decision making process

3.3. Who will be involved?

3.3.1. The RLDP, once adopted will guide the development and use of land across Swansea Council administrative area up to 2038. Therefore, the Council welcomes engagement from individuals and organisations in shaping this important strategy document which will become the main decision-making framework for the assessment of planning applications and to guide the Councils ambitious Placemaking agenda.

3.3.2. The LDP Regulations set out the legal requirements for community involvement and participation. This sets out that certain types of stakeholders need to be involved at specific stages of the RLDP process. These Specific and General consultation bodies are set out in Appendix 3 and will be consulted as considered necessary (see para 3.4.6). The Council will seek to exceed these requirements where considered necessary.

3.3.3. Appendix 4 sets out the detailed timetable for community engagement setting out which stakeholders will be involved at each stage. This sets out what the Council intends to do as a minimum in the preparation of the RLDP. Where time and resources allow the Council will aim to provide additional opportunities for engagement. To enhance engagement the Council's RLDP website will be updated regularly to keep stakeholders informed. Efforts will be made to make consultation processes as accessible as possible.

3.3.4. Community involvement throughout the development of the LDP should be a continuous process that enables the local community to be part of the decision making process; creating the sort of place they want to live in, at a stage when this can make a difference. The CIS sets out how the Council proposes to proactively engage with and involve the local community and stakeholders in the preparation of the RLDP. It will be important that the right people are involved at the right time to ensure effective frontloading of issues and to secure effective and meaningful engagement in the plan making process. The CIS describes the ways in which the community can influence the RLDP at the different stages of the Plan preparation process. The timetable set out in Part 2 and Appendix 1 should be read in accordance with this. The detailed CIS is set out in Appendix 4.

3.3.5. It is recognised that at certain stages it will be more effective to engage a targeted range of stakeholders or representative bodies. To keep participation effective, meaningful and manageable stakeholder events will be targeted to the most relevant bodies/representors. All statutory consultation stages will be subject to full public consultation. The Council will seek to involve the following external groups in preparation of the Replacement LDP:

3.4. External Groups

3.4.1. Members of the public, interested persons and organisations: The Council will produce and maintain a consultation database that includes interested individuals and organisations who have requested to be informed of the RLDP process (see para 3.17). Anyone with an interest in the future place-making and sustainable development of Swansea can be added to the database. We encourage interested parties to register their details so they can be kept up to date about forthcoming relevant consultations. Efforts will also be made to engage with communities, businesses, and local organisations to ensure a broad range of feedback. A list of these has been collated using contact details found online who will be notified to see if they wish to be contacted as part of future consultation stages. This is not an exhaustive list and any group not included in Appendix 3 can join the consultation database.

3.4.2. Community Councils: The existing network of Community Councils across Swansea will be a key contact for the dissemination of information within their local area and a link to their local area. Accordingly, the CC's will be consulted on all key stages and through their communication channels will assist the Council in raising awareness of the RLDP to their local constituents. The Community Councils will advise on the land use aspirations they have for their community so are encouraged to contribute to consultation stages. Specific reference should be paid to consultation stages to ensure meetings can be programmed early to ensure comments can be submitted within prescribed time periods.

3.4.3. Swansea Council Developer Forum: The Developer Forum is a key engagement group in delivering the Council's ambitious Placemaking agenda. The forum which is made up of local and regional developers, house builders, Registered Social Landlords and planning agents will be an Important asset as it brings groups involved in development in Swansea together with policy makers. The Council will engage with the Developer Forum to shape the future strategy but to also ensure that the timing and phasing of sites is robust and based on up to date information.

3.4.4. Partnership Groups: There a range of Partnership groups across Swansea who will have a potential interest in contributing to shaping the future land use plan. They can act as single points of contact for groups of people and, consequently, can play an important role in raising awareness of the RLDP, engaging the wider community and helping disseminate information. A key partnership group that the Council will engage with is the Swansea Public Service Board to ensure the RLDP aligns with the Local Well Being Plan. The PSB covers a range of interested parties who can contribute to the emerging RLDP and they will be actively involved during preparation of the plan.

3.4.5. Businesses and Landowners: Efforts will be made to engage the business community at key stages and interested businesses are encouraged to register their details on the LDP Database. A key part of the RLDP process will be the Call for Candidate Sites. Landowners therefore across Swansea who may have an interest in their land being considered for development will need to follow the Council's website for details of the Call for Candidate Sites process. This will set out the threshold for sites to be considered and the level of information required. All sites must be submitted during the Call for Sites consultation stage.

3.4.6. Consultation Bodies: The Specific and General consultation bodies in Appendix 3 will be engaged as considered necessary throughout the RLDP process at each of the formal consultation stages and informally as appropriate. Specific bodies include the Welsh Government and those bodies with specific functions that apply to the RLDP area (e.g., the Swansea Bay University Health Board and Dŵr Cymru Welsh Water). Authority must also consult UK Government Departments where aspects of the plan appear to affect their interests and concerns. Similarly, the SEA process requires specific 'Environmental Consultation bodies' to be consulted at key stages. These are National Resources Wales and CADW. General consultation bodies include bodies that represent the voluntary sector, different racial, ethnic, religious groups, disabled persons, business and welsh culture. In addition, the Council can also involve at its discretion' such other persons or groups who may have an interest in matters relating to development in the area'. These have been grouped under General Consultation Bodies and will be consulted as considered appropriate.

3.4.7. Seldom Heard Stakeholders: Seldomly heard stakeholders, are groups or individuals who have traditionally been absent in the plan preparation process. Additional effort will be required to ensure these stakeholders are represented albeit within the parameters of the specified participation/consultation periods and resource limits. These groups include but are not limited to:

• Young people and children
• People with disabilities
• Older people
• People with learning difficulties
• Homeless people
• Ethnic minorities
• Gypsies and Travellers

3.4.8. Key consultation groups representing some of the above interests have been identified, and the team will work with relevant Council contacts to identify the most appropriate forms of engagement with these groups as appropriate. For example trusted intermediaries may be used, as appropriate, in order to gain the views of particular groups or individuals who lack the confidence to engage directly in the process.

3.5. Within the Council

3.5.1. It will be important that the RLDP secures effective engagement from officers across the Authority as the land use strategy will deliver on the aims and objectives of a range of Council departments. Similarly, engagement from elected members will be of critical importance.

3.5.2. Councillors/Elected Members: Elected members of Swansea Council are crucial stakeholders in the Replacement Plan preparation because they represent individuals and communities within their ward. Therefore, members will play an essential role in the RLDP by providing information to local residents and informing the team of issues and opportunities in their area that need to be addressed as part of the plan. More widely members represent wider public interests as they are responsible for taking decisions on RLDP matters that go beyond ward level affecting the whole of the County. Engagement with members will be undertaken throughout the process of RLDP preparation which will involve as appropriate briefing on issues through members seminars at key stages, presentation of statutory stages to Council and will be notified prior to each consultation stage. The Cabinet member (Cllr David Hopkins) with responsibility for the Local Development Plan will be closely engaged in the preparation of the RLDP.

3.5.3. LDP Member Advisory Groups: It is proposed that relevant Members are convened with suitable regularity to provide an opportunity to focus exclusively on issues relating to the LDP. The make up of the group is to be decided but could include Cabinet members and have representation from across parties. This will facilitate continued engagement with senior members and officers throughout the plan preparation process. It will provide opportunities to inform and consult Councillors at various stages of LDP preparation and provide a sounding board for issues arising.

3.5.4. Corporate Policy Team: Officers leading on the RLDP will work closely with the Council's Corporate Policy Team who support the delivery, co-ordination and administration of the Public Services Board and lead the Council's contribution to the Local Well-being Plan.

3.5.5. Scrutiny : All scrutiny activity within the Council is managed by the Scrutiny Programme Committee. Where necessary LDP preparation will be monitored by the Development and Regeneration Performance Panel.

3.5.6. Officers: Officers from a range of service areas will provide key inputs into the development of the RLDP. Key engagement will occur with departments throughout the process including officer engagement workshops. A RLDP officer working group may be set up to facilitate this process.

3.6. Analysis of Previous CIS Strategy

3.6.1. The Council has reviewed the previous CIS to inform the development of the CIS for the RLDP. Specifically, given the improvements in technology and the experience learned from the COVID-19 pandemic in terms of changing working practices the RLDP will now rely on greater use of a more digital focused strategy for engagement for disseminating information which will reach a wider audience and will focus on opportunities to better engage seldom-heard groups. In addition, it is considered improvements can be made to make the webpages more streamlined and accessible, the use of a dedicated consultation software to assist in facilitating electronic submission of representations and also the preparation of summary leaflets/easy read of key documents as appropriate to make consultation documents more accessible to a wider demographic of stakeholders. This review is set out in Appendix 5 setting out aspects that went well and identifies areas that could be improved upon.

3.7. Methods of Engagement

3.7.1. There are a large number of different consultation methods and it is important that the correct ones are used. The CIS sets out potential methods of engagement and at which stage of the RLDP they may be used. In delivering the Community Involvement Scheme the RLDP team will utilise the consultation toolkit to help facilitate the most appropriate opportunities and will liaise with the Councils Consultation Coordinator in the detailed planning of future consultations. Details of the emerging RLDP consultations will be widely publicised to reach as much of the community as possible, to inform people and set out how they can become involved. Methods of engagement may include:

• Direct contact (preferably by email, or letter)
• RLDP information posted on RLDP webpages
• Engagement with Elected Members via members seminars
• Public Meetings/Virtual Meetings
• Press releases
• Production of Summary Leaflets / Easy Read versions of consultation material
• Social Media (e.g. Facebook, Twitter)
• Drop in sessions
• Surveys
• Focus Groups
• Workshops
• Deposit of documents in main Council offices, libraries, Customer Contact Centre where appropriate
• Public exhibitions
• Webinars
• Site Notices displayed regarding proposed land allocations at Deposit Consultation stage

3.7.2. It is clear from the review of the previous CIS that engagement needs to take into account the individual needs of those who want to take part. Therefore, the Council will seek to get the appropriate balance considering time and officer resources between in person engagement alongside virtual engagement and will maximise the distribution of information digitally but will also present consultation information in paper form as appropriate.

3.8. Stakeholders – What we expect of you

3.8.1. In order to ensure stakeholder comments can be considered as part of key consultation stages they must be 'duly made'. That is they must be submitted within the prescribed timescales. Table 2 below and the CIS in Appendix 4 sets out the timescales where key consultation stages will be undertaken and where we will seek your involvement with specific details of the exact consultation dates published near the time of the proposed consultation. Ensuring representations are duly made will be key to ensuring your views can be taken into account.

3.8.2. Responses should be considered carefully to ensure they raise legitimate issues that can be addressed by the RLDP and the Planning system. Information should be provided in a clear and accessible format and take account of any guidance forms produced by the Council to assist in making representations.

3.8.3. The consultation timescales cannot be extended to take account of meeting cycles of community groups. At the statutory stages the Council does not have the flexibility to change the periods of consultation from that prescribed in the Regulations/detailed in the CIS.

3.8.4. Where consultation bodies identify gaps in the evidence base or information provided they should seek to support the Council in improving the evidence base in the interests of achieving a 'sound' RLDP.

3.8.5. It is also important that you notify the Placemaking & Strategic Planning Section should your contact details change during the RLDP process for officers to keep you fully informed and updated of any progress. Regarding candidate sites, land ownership changes may also occur during the process, and it is imperative that these are updated by contacting the LDP team in order to ensure progress is not delayed.

3.8.6. Finally whilst LDP matters can be emotive we request that officers are treated with respect.

3.9. What stakeholders can expect of the Council

3.9.1. The Council will seek to adhere to the published timescales in the DA and make all information available on time. In this case it will seek to facilitate engagement with the right people at the right time in the preparation of the RLDP to ensure meaningful and effective consultation and efficient use of resources. Whilst the Council will do all it can to comply with the commitments set out in the DA, there may be a need to be flexible and adapt to circumstances at the time. The RLDP CIS process will facilitate early and effective community involvement. A range of methods to publicise consultation stages and provide early warning of key consultation stages and to provide community updates will be used to engage effectively throughout the process. Where comments have been invited on particular documents it will be clear how comments will be considered and stakeholders will be notified when feedback is available. To facilitate engagement during key consultation stages an interactive web based consultation and engagement system to record representations will be put in place.

3.10. Consensus

3.10.1. The CIS will seek to build consensus through meaningful engagement. In order to achieve this, it is important that participants are kept fully informed throughout the process from the outset. Effective engagement involves using various methods, setting realistic aims and facilitating an open and honest debate. However, the Council recognises that consensus may not be achieved in all situations. It is vital, therefore, that the decision making process is transparent whereby each decision made has a clear audit trail so those who may disagree are assured that their opinions have been considered and the decisions have been made in an informed and balanced manner.

3.11. Handling Representations and Feedback

3.11.1. The Council will seek that feedback is provided online as soon as possible on the outcome of engagement and consultation throughout the RLDP process. It is proposed that a new consultation software will be in place within which to submit consultation responses. Representations that are received within the appropriate timescales will be handled during each stage of plan preparation in the following manner:

• Representation is logged and given a representation number;
• Confirmation is sent to a representor of receipt of the representation with details of next steps in the process;
• All valid representations are considered, responses are formulated; and

A report of consultation will be prepared which will be published at an appropriate time containing a schedule of representations and the Councils response to those together with any proposed actions necessary as a result of the representation.

3.12. Late Representations

3.12.1. The RLDP process is subject to both statutory and non-statutory consultation/involvement periods, which have defined periods for submissions. For responses to be 'duly made' and thus considered, they are required by the specified deadline of these consultation periods. Any comments/representations submitted after the deadline dates will not be considered 'duly made' for the purposes of the RLDP Examination. This is to ensure the process is fair and equitable for all those parties involved in the process.

3.13. Council Decision Making process and Local elected Member involvement

3.13.1. Prior to statutory public consultation stages key decisions on RLDP documents will be made by Full Council following presentation if appropriate to Cabinet with meetings taking place every four weeks.

3.14. Welsh Language and Bilingual Engagement

3.14.1. The Welsh Language Standards place a legal duty on Councils to make it easier for people to use services through the medium of Welsh. The Council has published a 5 year strategy for the Welsh language and the requirements of the Welsh Language Standards will be maintained at each stage of the Replacement LDP. Bilingual engagement will be carried out in the following ways:

• We welcome correspondence in both Welsh and English. Where correspondence is received in Welsh and a reply is necessary, this will be sent in Welsh;
• All consultation letters, comments forms, public notices (including site notices) and newsletters will be bilingual;
• Any pages on the Replacement Local Development Plan website and social media posts published on twitter will be bilingual;
• Any public meetings will be conducted bilingually where a request has been made ahead of time. Prior notification is required in order to provide a translation service; and
• The Replacement LDP once adopted will be available in both Welsh and English Format.

3.14.2. The RLDP will be subject of an integrated Sustainability Appraisal which will include an impact of the plan on the Welsh Language as part of this.

3.15. Key Stages of RLDP and opportunities for Engagement

3.15.1. The LDP Regulations set out the legal requirements for participation and public consultation in Replacement Plan preparation. The detailed timetable for community engagement and the potential engagement methods for the key stages in the LDP preparation process are highlighted in Appendix 4. The list itself is not exhaustive and could require adaptation to ensure the community and stakeholders are appropriately involved at each stage. The section below provides a summary of the key stages and when stakeholders can become involved. Information will be constantly updated on the RLDP webpages and notification of consultations emailed to stakeholders registered on the LDP database.

3.16. Availability of Documents

3.16.1. All RLDP documents will be made available to view and download on dedicated Replacement LDP webpages. In addition, in accordance with the LDP Regulations all relevant documents will be made available for public inspection at the principal office during normal office hours:

Civic Centre
Oystermouth Rd
Maritime Quarter
Swansea

3.16.2. During the statutory public consultation stages (Preferred Strategy and Deposit Plan consultation) as identified in Table 2 above hard copies of the main consultation documents, where possible, will be placed in all the 17 libraries for public inspection. Currently the public library venues are: Bonymaen, Brynhyfred, Central, Clydach, Fforestfach, Gorseinon, Gowerton, Killay, Llansamlet, Morriston, Oystermouth, Penlan, Pennard, Pontarddulais, Sketty, St Thomas and Townhill.

3.17. RLDP Consultation Software

3.17.1. The Council has implemented a new consultation software system to support the RLDP. Stakeholders will be able to register their details online via this system and can then submit comments at appropriate consultation stages and will be notified of future consultations on the RLDP. To register your details please visit:

Swansea Council - OpusConsult (oc2.uk)

3.17.2. The consultation system will be managed in line with General Data Protection Regulations (GDPR). Any parties wishing to register will need to agree to the Council’s Privacy Notice setting how the Council will use consultees’ information and to confirm acceptance for your details to be held for the purposes of RLDP communication only. Stakeholders can register their details anytime during the process.

3.17.3. Anyone who makes representations at any of the stages of the RLDP will be deemed to have given their consent and will be added to the system in order to administer their comments and for them to be adequately informed of further opportunities to participate at a later date in the process. However, if you wish your details to be removed from the system then you will be able to unsubscribe and your details will be removed for future consultations.

3.18. Contact Details

Further information on the RLDP process can be gained by visiting the Councils website at:

Placemaking and strategic planning - Swansea

Or for those unable to access the Councils website, further information can be gained by contacting the team at:

Email: ldp@swansea.gov.uk

Placemaking and Strategic Planning
Swansea Council
Civic Centre
Oystermouth Road
Maritime Quarter
Swansea
SA1 3SN

Comments are welcome in Welsh and English