Knowsley’s Broken Democracy, Part 1: Knowledge Is Power
The first in a series of opinion pieces by the editor
(Too long didn’t read? The gist: Knowsley Council provides information that no one can understand, and without information, you are powerless.)
A great philosopher – no one’s quite sure who, but Sir Francis Bacon seems to be the main candidate – once said that ‘knowledge is power.’ If you want to play a meaningful role in the world around you and make a difference but are denied information, you are left powerless. Those in the know hold the cards.
As a journalist who quite often has to navigate the murky maze that is knowsley.gov.uk, I can say with confidence that Knowsley Council’s website is a disaster for local democracy. This, in an age when the world wide web is people’s first port of call to find facts and public information. Whether by design or not, the Knowsley Council website does little to help people access information and lots to hinder it.
Knowsley’s Local Plan: A Communications Nightmare
Our case in point is the recent consultation on the Local Plan, which Knowsley Council voted through unanimously in the face of huge public opposition. The controversy stemmed from the fact it removed protections from vast areas of the borough’s greenbelt, meaning that formerly protected open space can now be sold and developed for housing. (Click here for a brief summary of the arguments for and against.)
Anyone wanting to find out more about the Local Plan and what it entailed was directed to www.knowsley.gov.uk/residents/building-and-planning/local-plan. Here is our first obstacle. Where to click?
“Introduction to the Local Plan” would seem an obvious place for the average resident to start finding out more.
We have fallen at the first hurdle. Try getting your head round this nonsense:
The Knowsley Local Plan contains the statutory planning policies for the borough, which will guide investment and development.
The term ‘Local Plan’ was introduced by the National Planning Policy Framework (NPPF) in March 2012, and builds upon work completed under the previous Local Development Framework (LDF) system introduced by the Planning and Compulsory Purchase Act 2004. The Local Plan is strategically linked to the Sustainable Communities Strategy (SCS). The current adopted plan for Knowsley is the Replacement Unitary Development Plan (2006); this will remain in place until the formal adoption of the emerging Core Strategy.
Does Knowsley Council expect an ordinary resident to understand all this jargon? Is this the language of a council that wants to communicate clearly with the public? It is anything but plain English.
Anyone who can wade through such terms as “National Planning Policy Framework,” “Local Development Framework,” “Planning and Compulsory Purchase Act 2004,” “Sustainable Communities Strategy,” “Replacement Unitary Development Plan” and “emerging Core Strategy” will be rewarded with a few words that make more sense – “housing” and “retail,” for example – but I wonder how many residents make it that far without a degree in planning policy?
Before the council voted in early 2016 to adopt the Local Plan, if you’d wanted to go straight to the relevant documents, you’d have clicked “Examination 2015.” Let’s try it.
Now, without consulting a lawyer or a government adviser, try finding the information you’re looking for in this labyrinth of meaninglessness:
Key Modifications Documents – July 2014 Hearings
EX29 – Council Letter to Inspector re: Modifications 26.06.14
CS08 – Knowsley Local Plan Core Strategy – Schedule of Proposed Modifications to the Submission Document
CS08a – Erratum Sheet for Scedule of Proposed Modifications – Minor Changes
CS09 – Knowsley Local Plan Core Strategy – Submission Document Incorporating Tracked Changes
CS10 – Knowsley Local Plan Core Strategy – Proposed Modifications to the Policies Map
Key Modification Documents – Autumn 2014 Public Consultation
CS08c – Knowsley Local Plan Core Strategy – Schedule of Proposed Modifications to the Submission Document – Consultation Version –
CS09a – Knowsley Local Plan Core Strategy – Submission Document Incorporating Tracked Changes – Consultation Version (NB this is the latest version of the Core Strategy incorporating modifications)
CS10a – Knowsley Local Plan Core Strategy – Proposed Modifications to the Policies Map – Consultation Version
SD32 – Proposed Modifications – Sustainability Appraisal Report
SD32a – Proposed Modifications – Sustainability Appraisal Non-Technical Summary
SD32b – Proposed Modifications – Sustainability Appraisal Appendices
SD29 – Proposed Modifications – Habitats Regulations Assessment (Part One)
SD29a – Proposed Modifications – Habitats Regulations Assessment (Part Two)
Key Modification Documents – Autumn 2015 Public Consultation (Wind Energy)
CS11 – Knowsley Local Plan Core Strategy – Schedule of Further Proposed Modification to the Submission Document – Consultation Version
SD36 – Further Proposed Modification – Sustainability Appraisal Report
SD37 – Further Proposed Modification – Habitats Regulations Assessment
SD38 – Knowsley Local Plan Core Strategy – Additional Wind Energy Consultation Report of Representations
We could try the “Examination Library” instead, but look at the gobbledy-gook we are faced with:
Examination Documents (EX)
This includes documents submitted by the Inspector and the Council during the examination, and items from the Programme Officer.
This also includes all hearing statements submitted by the Council (CH) and Representors (RH, RC), as well as additional evidence base and supported documents (AD) submitted during the Examination process.
Core Strategy Documents (CS)
This includes only key consultation documents published as part of the preparation of the Knowsley Local Plan Core Strategy. The documents include previous consultation versions of the Core Strategy, including the Issues and Options Paper and Preferred Options Report, as well as the Proposed Submission and Submission Documents.
Council Reports and Minutes (CR)
The Knowsley Cabinet have approved the Core Strategy at each key stage of its development: Issues and Options, Preferred Options and Proposed Submission. The Proposed Submission Core Strategy was also approved by the Council. These documents include the reports sent to both Cabinet and Council and the minutes from the relevant meetings.
Knowsley Evidence Base (EB)
These documents have been produced by the council, and in some cases commissioned expert consultants, to provide primary and secondary research to inform and justify planning policy decisions, including those set out in the Knowsley Local Plan Core Strategy. Evidence base documents cover a wide range of issues affecting Knowsley, including housing land supply, economic viability, greenspaces and playing pitches, and flood risk assessments.
Legislation and Regulations (LR)
This category includes the planning related legislation and regulations produced by national government which influenced the development of the Knowsley Local Plan: Core Strategy.
Liverpool City Region and Regional Evidence Base (LC)
These are evidence base documents prepared for a wider area than the Borough, including studies commissioned on a sub-regional basis, or across a number of neighbouring authorities.
Planning Policy Documents (PP)
This includes all non-Core Strategy planning policy documents produced by the Council, including the adopted Unitary Development Plan, the Merseyside and Halton Joint Waste Local Plan, as well as a range of adopted Supplementary Planning Documents. This category also includes process documents produced to support the Local Plan, including Monitoring Reports, the Local Development Scheme and the Statement of Community Involvement.
Policy and Guidance (PG)
This contains national, regional and local policy documents which have informed the policies in the Core Strategy. This includes the National Planning Policy Framework (NPPF), the now abolished Regional Spatial Strategy, City Region Strategies and local policies and guidance for Knowsley.
Supporting Documents and Assessments (SD)
These documents have been produced specifically to support the Core Strategy. The documents include the results of previous consultation exercises, as well as the reports of assessments including the Sustainability Appraisal, Habitats Regulations Assessment, Health Impact Assessment and Equality Impact Assessment. The Infrastructure Delivery Plan, Monitoring Framework and Duty to Cooperate Statement can also be found within this category.
Technical Reports (TR)
These documents have been produced by the Council specifically to support the preparation of the Knowsley Local Plan Core Strategy. The technical reports cover a range of topics, and are intended to provide a bridge between evidence base documents and the policies in the Core Strategy document. These reports have been designed to be easy to navigate, and to succinctly set out reasoned justifications for a number of different Core Strategy policies.
Do you have a headache yet?
Does any Knowsley councillor or council offer feel this is an appropriate, meaningful or even vaguely helpful way of presenting information to Knowsley residents?
Once the decision had been made (on 6 January 2016), you could go to “Adopted Documents” to see the final results for yourself.
There are a number of different planning policy documents in place for Knowsley. These include statutory documents in the Local Plan, other planning policy documents and process documents.
Local Plan Core Strategy
The Knowsley Local Plan Core Strategy was adopted in January 2016. The full adoption version of the document is available below:
Knowsley Local Plan Core Strategy 2016 (9MB)
The following documents are published alongside the Core Strategy.
Local Plan Core Strategy Adoption Statement (134KB)
Local Plan Core Strategy Sustainability Appraisal, consisting of the following documents:
Proposed Submission Document (October 2012) (SD07) and Appendices (SD07a)
Green Belt Locations (June 2012) (SD08) and Appendices (SD08a)
Proposed Modifications (September 2014) (SD28), Non-Technical
Summary (SD28a) and Appendices (SD28b)
Further Proposed Modification (August 2015) (SD36)
You can view the Inspector’s Report issued in November 2015 here. The Inspector’s Report contains (within its Appendix) a schedule of the “Main Modifications” included in the Plan.
The Plan also incorporates further modifications proposed and approved by the Council in January 2016:
Schedule of Additional Modifications (2MB)
Schedule of Minor Changes and Edits (506KB)
These documents are available to view in Council libraries and One Stop Shops. Please see the Adoption Statement for further details.
Unitary Development Plan
The Knowsley Replacement Unitary Development Plan was adopted in June 2006. The full document is available below:
Knowsley Replacement Unitary Development Plan 2006 (1.3MB)
Under the transitional arrangements for moving to the Local Plan system, all but four of the 82 individual UDP policies were “saved” by the Secretary of State on 12 June 2009. An additional three UDP policies were replaced on adoption of the Merseyside and Halton Joint Waste Local Plan (see below). A further 36 policies were deleted on adoption of the Local Plan Core Strategy.
This leaves 39 UDP Policies which continue to be saved. The Local Plan Core Strategy Appendix C gives a full schedule of which UDP Policies continue to be saved.
Adopted proposals map
The adopted version incorporates amendments made following the adoption of the Waste Local Plan in July 2013 and the Local Plan Core Strategy in 2016.
The Policies Map is available as an interactive tool on the following link:
Local Plan Policies Map
Merseyside and Halton Joint Waste Local Plan
The Merseyside and Halton Joint Waste Local Plan was adopted as part of the Local Plans of the six constituent authorities in July 2013. The Plan provides a range of policies and site allocations aimed at supporting a sustainable waste management framework for the Liverpool City Region for the period up to 2027.
The Plan is available to download below, accompanied by a set of site profiles and the final Inspectors Report relating to the soundness of the Plan.
Merseyside and Halton Waste Local Plan
Waste Local Plan Adoption Statement
Waste Local Plan – Final Inspectors Report
Implementation and Monitoring Reports relating to the Waste Local Plan are available on the Merseyside Environmental Advisory Service website.
Further information regarding the Merseyside and Halton Waste Local Plan, please visit the or Merseyside Environmental Advisory Service website please contact the Waste Local Plan team on 0151 934 2804 or email firstname.lastname@example.org
Supplementary planning documents
Other Planning Policy documents include those documents which are outside of the statutory development plan, like Supplementary Planning Documents (SPDs). These support the policies in the Local Plan, and can provide further guidance for development on specific sites, or on particular issues.
Local Development Order
The Local Development Order (LDO) will apply to all of the land within Knowsley Industrial and Business Parks, and its overall purpose is to support the regeneration of the Parks and to maximise the contribution they make to the local and sub-regional economy. It will achieve this by simplifying the planning permission requirements for the area, and in so doing support existing businesses, stimulate additional investment and help deliver improvements to the public realm and image of the area.
Knowsley Industrial and Business Parks: Local Development Order and Statement of Reasons
Knowsley Industrial and Business Parks: Local Development Order Design Code
Process Documents support the Local Plan preparation process, including scheduling the preparation of Local Plan Documents, setting standards for community engagement and monitoring progress.
I will leave it to you to decide whether the final version of Knowsley’s Local Plan (and I defy anyone to find it on Knowsley’s website without a compass, an A-Z and a qualified tour guide) is an improvement, even with its shiny, appealing front cover.
Knowledge is power, right? Do you get the impression Knowsley Council has all the knowledge and is making it as hard as possible for you to get to it? Is it by design, or is it just sloppiness? Is it deliberate, or does Knowsley Council just not care? Are we being hoodwinked on purpose, or is it just incompetence?
It almost doesn’t matter, because the end result is the same – we don’t have access to the facts, and without them we are powerless.
This is not a minor issue. Democracy is a two-way street that involves communication between the representatives and the people who elected them. What hope do we have if we speak two different languages and there is no one to interpret?
Rarely have we seen such strength of public feeling as we have over the Local Plan and its consequences for the borough’s greenbelt. If the council fails so badly to provide access to information to the average Knowsley resident, something in the system is fundamentally broken.