This support was required to ensure that it successfully completed two consultation stages as follows:
- Consultation under Regulation 18 on a draft version of the Plan
- Consultation under Regulation 19 on the proposed submission Plan
The West Sussex Waste Local Plan proposed several sites for waste management, including thermal treatment. Each site provoked controversy due to the perceived nature of the impacts that would arise if a facility were to be developed.
For the consultation on the Draft Plan, BPP Consulting carefully prepared a consultation programme which involved an assessment of the stakeholders who needed to be consulted and an action plan for maximising the likelihood of these stakeholders becoming aware of the consultation and providing a response. The consultation programme also identified the need for explanatory publications. At all times the programme was prepared with an awareness that waste consultation and stakeholder input is a key element of ensuring that the Plan passes the legal compliance (including Duty to Cooperate) and soundness tests. With this in mind a thorough process was designed which would enable the authorities to effectively defend any challenge that the Plan had not been prepared with appropriate input from communities and other stakeholders.
The main categories of stakeholder identified were:
- Residents of West Sussex
- Residents living in close proximity to the proposed sites
- Parish Councils
- Pre-established Community Liaison Committees
- District and Borough Councils
- Neighbouring and more distant Waste Planning Authorities
- Local waste management industry
- Statutory Bodies e.g. Environment Agency, Natural England etc.
Methods of engagement included the following:
- Mailout/email to all stakeholders registered on the County Council’s Waste Local Plan consultation database
- Press Releases – one at the start and one towards the end of the process
- Evening presentations to Community Liaison Committees
- Presentation of information on the authorities’ websites including development of on-line response forms
Input to the Communications Programme was obtained from WSCC Communications Officer to ensure the consultation process met corporate standards for communicating with customers (e.g. ensuring that publications were prepared using the house style) and materials were written in ‘plain English’. As the Plan is joint with the South Downs National Park Authority similar liaison was also necessary. The programme was also designed to ensure that, as required by the regulations, it followed the approach set out in the both Authorities’ Statements of Community Involvement.
This programme of consultation elicited over 100 responses. In particular, the consultation drew out a landowner’s dissatisfaction with the inclusion of a particular site which lead to it being withdrawn from further consideration. It should be noted that it was important to establish the landowner’s position at this stage otherwise this may have resulted in the site, and possibly the entire Plan, being found undeliverable leading to difficulties with the Plan passing the deliverability soundness test. The consultation also identified uncertainty in the position of the landowner at a different site. Through a series of meetings and conversations, the landowner’s position was clarified and the site was included in the Proposed Submission Draft Plan with the reassurance that it had landowner support.
There is no doubt that the Plan was controversial but by being open and by showing a willingness to meet and discuss the Plan, the authorities were seen to be genuinely wishing to engage with local communities and were not open to the charges often levelled at officialdom that information had been witheld or deliberately concealed.