An applicant's community involvement statement on a small site
Consultation on a small scheme is not required by statute, and doing it properly still changes the outcome. The document is a record of what you did and what you changed.
An applicant's statement of community involvement records who you consulted about your scheme, how, what they said and what you changed as a result. It is a different document from the council's own statement of community involvement, which is the authority's published policy on how it consults, adopted under section 18 of the Planning and Compulsory Purchase Act 2004. Confusing the two is common and it produces a document that describes the council's procedures instead of your engagement.
Below the major development threshold, which is ten or more dwellings, a site of 0.5 hectares or more, or 1,000 m² of floorspace, there is no statutory requirement to consult before applying. Some local validation lists ask for a statement anyway, and on a contested small site it is worth producing whether or not it is required.
What the statement is for
Three things, in descending order of usefulness.
It tells the case officer that the objections in the file have already been heard and addressed, which changes how they read them. An officer facing fourteen objections and no engagement assumes a scheme parachuted in. The same fourteen objections alongside a record of a meeting, a design change and a written response read very differently.
It gives the parish or town council something to respond to before they write their formal comment, which is usually drafted at a single monthly meeting with no opportunity to ask questions.
And it protects you at appeal, because an inspector can see that the concerns were considered rather than ignored.
What it is not is evidence of support. A statement claiming that the community welcomes the proposal, based on a handful of conversations, damages your credibility on everything else in the file.
Deciding who to consult and how far
Draw the consultation area from the effects of the scheme rather than from a standard radius.
Immediate neighbours are those whose outlook, light, privacy or access changes. Take the properties the council will notify and add any the notification will miss, which on a rural plot often means the house across a field with the only view of the site.
Beyond that, think about who has an interest in the specific issues. A scheme on a lane with no footway involves everyone who walks it. A conversion in a conservation area involves the local amenity society. A site next to a school involves the school.
The parish or town council should always be on the list below the major threshold, because it is the body most likely to be asked for a view and the least likely to have any information beyond the application documents.
Methods proportionate to a small scheme
For one to nine dwellings, the methods that work are simple and direct.
- A letter or leaflet to a defined list of addresses, with a plan, a short description, your contact details and a date by which comments are welcome.
- An offer to meet on site or at the neighbour's house, taken up by more people than you expect.
- A short conversation with the parish clerk, followed by attendance at a meeting if invited.
- A single sheet left with the immediate neighbours showing the proposed elevations, because most people cannot read a site plan and can read an elevation.
- An email address that is monitored and a reply to every message received.
An exhibition, a website and a feedback form are appropriate for a scheme of 50 units and are disproportionate for four. Doing too much on a small site looks like process rather than engagement, and it costs money that would be better spent on the drawings.
Give people a fortnight and say when you will come back to them. Consultation that closes with silence is worse than none, because it confirms the suspicion that the exercise was cosmetic.
Recording feedback honestly
Keep a log from the first conversation. Date, who, how they were contacted, what they raised, and your response. It takes minutes at the time and is impossible to reconstruct later.
Group the points by theme when you write them up: overlooking, parking, drainage, construction disruption, character. Then set out, for each theme, what was said, whether it led to a change, and if not, why not.
Report the points you did not accept. A statement that lists five concerns and says all five were addressed is less persuasive than one that says three were addressed, one was already covered by a condition the council will impose, and one could not be met because moving the building would put it in the flood zone.
Do not name individuals. Use "a neighbour on the north boundary" rather than a name and address, and keep the underlying log separate. Publishing a neighbour's name and their objection in a public document is a poor start to a relationship you will have during construction.
Showing how the scheme changed
This is the section officers actually read, so make it easy to see.
A before and after pair of drawings, with the changes annotated, does more than three pages of text. Typical changes that come out of small site consultation: a first floor window moved or obscure-glazed, a roof form lowered on the boundary side, a bin store relocated, a hedge retained rather than removed, construction access moved to a different point.
Quantify where you can. A ridge lowered by 600 mm is a fact. An improved relationship with the neighbouring property is not.
Where the scheme did not change, say so plainly and give the reason. The commonest honest answer is that the change requested would have made the development undeliverable, and that is a reasonable position to state.
What not to claim
Four things to avoid, because each of them invites a rebuttal in the objection file.
Do not claim consensus. Do not describe objectors as a small minority. Do not present attendance figures as support. And do not state that the parish council supports the scheme unless it has resolved to do so at a meeting and you can cite the minute.
Equally, do not use the statement to argue the planning merits. That belongs in the Planning Statement, and mixing the two makes the consultation record look like advocacy. Keep the statement factual: this is what we did, this is what we heard, this is what changed.
How officers use the document
A case officer reads it in about four minutes, looking for whether the neighbours who objected were consulted, whether the objections in the file match the themes you reported, and whether the changes you claim appear on the submitted drawings.
A mismatch between the log and the objection file is the thing that undermines the document. If a neighbour objects saying they were never contacted, and your log says otherwise, the log needs to show the date and method or the whole statement loses weight.
Where the scheme is refused and appealed, the statement becomes part of the appeal documents, and an inspector reads it for the same three things. The Statement of Community Involvement page sets out the structure in more detail, and the Design and Access Statement is where the design response to what you heard should be explained.
One last practical point. Send the final statement to the people who took part, with a note saying the application has been submitted and giving the reference. It costs nothing, and the neighbour who feels informed is a different correspondent from the neighbour who finds a site notice on a lamp post.
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Frequently asked questions
Is community consultation required for a small planning application?
Not by statute below the major development threshold of ten dwellings, 0.5 hectares or 1,000 m². Some councils ask for a statement through their local validation list, and the National Planning Policy Framework encourages early engagement. On a contested site it is worth doing whether or not it is required.
What is the difference between the council's statement and mine?
The council's statement of community involvement is its published policy on how it consults, adopted under section 18 of the Planning and Compulsory Purchase Act 2004. Yours is a record of the engagement you carried out on this specific proposal, what people said and what you changed. They are different documents with different purposes.
How long should I give people to respond?
About two weeks is proportionate for a small scheme, with a stated closing date and a commitment to reply. Longer periods lose momentum and shorter ones look token. Say when you will come back to people, and then do so, because a consultation that ends in silence confirms the suspicion that it was cosmetic.
Should I name objectors in the statement?
No. Describe them by location, such as a neighbour on the north boundary, and keep the underlying contact log separate from the submitted document. Publishing names and addresses alongside objections is unnecessary for the planning purpose and makes the relationship during construction harder than it needs to be.
What if the consultation produced no changes to the scheme?
Say so and explain why, point by point. A statement recording that three concerns were raised, one was addressed by a change, one is dealt with by a condition and one could not be met without making the scheme undeliverable is more credible than one claiming everything was resolved.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.