UK Ministry of Housing, Communities and Local Government (MHCLG) 
Introduction
Statutory consultees are the organisations which Local Planning Authorities (LPAs) like Southampton City Council are legally required to consult before reaching a decision on Local Plan applications. They play an important role as experts in their particular specialism, together ensuring plans are physically feasible, won’t cause damage or harm and will ideally enhance the environment. Engaging statutory consultees effectively as Local Plans are developed is key, and this case study uncovers the role digital tools could play and considerations including barriers to adoption.
Challenge
Southampton City Council launched a digital consultation platform in 2022 as part of modernising their planning process and it was well received by citizens overall. However, it was noticed that the majority of the statutory consultees involved in consultations didn’t use the new platform. Instead, statutory consultees often provided their responses to consultations in the form of emailed PDF documents which were time-consuming for the LPA to process, with planning officers assimilating and analysing the emailed information. The rationale for statutory consultees responding with PDF documents instead of using the digital consultation platform was not understood by the LPA.
Therefore, the challenge for this PropTech Innovation funded project was for Southampton City Council to understand the barriers to statutory consultees using the new digital consultation platform and to test alternatives as well as build a deeper understanding of their processes.
Approach
Three national organisations were identified as being key statutory consultee participants for this pilot: Environment Agency, Historic England, and Natural England. In addition, the Home Builders Federation and Southampton Voluntary Service were invited to participate.
Using PropTech Innovation funding, the LPA collaborated with the statutory consultees to explore why the existing digital consultation platform did not suit their needs as well as identify the processes the statutory consultees must go through when preparing responses to consultations using user journey mapping. They also agreed to pilot an alternative digital platform specifically for statutory consultees when responding to Local Plan consultations. This was to demonstrate whether an alternative digital solution could work for both the LPA and statutory consultees.
Konveio was chosen by Southampton City Council as an alternative digital platform provider, able to present the whole Local Plan, in a PDF style, with the ability for statutory consultees to ‘click and comment’. Extensive user testing of the platform with the statutory consultees was carried out.
Results
The pilot aimed to identify the barriers for statutory consultees in using the digital consultation platform and test an alternative. Several barriers were uncovered including:
- The structure of the original consultation platform was designed for the general public but did not work well for statutory consultees who need to see the whole proposal at once, not each individual policy
- The statutory consultees requested Local Plan policy GIS (geographical information systems) layers so they could look at these alongside their own data. When viewed, there were accessibility issues with colours/patterns
- The sign-up process to log in to the platform and the digital competency of users
- The request to use the digital platform was not mandated so less pressure to comply was felt to implement this change in approach
- Resistance was felt towards changing processes from the current one involving thorough note-taking systems already running.
The statutory consultees found the trial beneficial. It provided their first opportunity to come together with each other and LPAs to discuss these issues and they found there were common themes and built good relationships and potential to work together in future.
The trial helped break down barriers as it gave the LPA the opportunity to share their side of the planning process and statutory consultees a chance to share their processes. All agreed that digital solutions could play a vital role in improving the user journey for LPAs and statutory consultees. The pilot helped to kick start conversations about the role of statutory consultees in the Local Plan process.
Next steps
Work with Konveio is continuing and their product is being refined and developed further in line with feedback, particularly around accessibility and requirements to choose colour and patterns for displaying data layers. Within another element of the project, Southampton City Council are working on a 3D (three-dimensional) webmap, which will bring GIS data together in 2D (two-dimensional) and 3D, and address accessibility requirements. Further exploration of artificial intelligence is underway to assist with analysis and summarisation tasks so officer time can be focused on the complex responses. The Ministry of Housing, Communities and Local Government’s policy team is also looking at ways to support statutory consultees in the Local Plan process.