Are you about to consult on your Local Plan? Read this first.

Why going beyond the statutory minimum is the smartest move your council can make.

Every Local Plan consultation is a test of trust. Councils and Councillors know that, communities sense it, and Inspectors see it. But because of the complexity of consulting such a vast number of people on such a complex piece of policy, engagement often ends up treated as a statutory hurdle rather than an opportunity to build legitimacy, especially when Officers are drowning in the workload associated with producing a plan. It is easy, and understandable, that aspirations for consultations hit reality. But what’s the result? A process that technically ticks the boxes but leaves residents cold and Councillors exposed.

As someone who’s delivered Regulation 18 and 19 consultations, I’ve looked at processes undertaken by LPA’s across the country and have seen what happens when teams achieve compliance instead of credibility. The difference isn’t just cosmetic, it can determine whether a plan survives examination, and in some cases if Councillors are booted out by the public at the next election!

The legal baseline — and its limits

Statutory consultation requirements under the Town and Country Planning (Local Planning) Regulations are, frankly, minimal. They may be supplemented by the Council’s own SCI, but it wont be specific to the precise needs a planning engagement programme needs. A council must invite representations, publicise its documents in local libraries or similar, and allow a set number of weeks. It’s all very 1990’s. Case law has established that Councils must undertake a period of conscientious consideration. But the consideration that needs to be given, will directly tie to what and how much you ask.

That’s where many plans fall short. The Gunning Principles are often treated as risk checklists rather than live standards. In reality, these principles are the foundation of procedural fairness and Inspectors increasingly expect authorities to show how they’ve upheld them.

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In 2024 alone, 26 Local Plans were adopted, more than the five-year average, but many others remain delayed or stalled. While hard numbers are a moving feast, current data suggests that 40–60 Local Planning Authorities may now be experiencing delays, stalls, or withdrawals of their Local Plan. Given that many others operate with out-of-date plans, the true scale of disruption is likely higher.

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The real-world expectations

Communities expect more than a notice in the local paper (that’s if one still exists in their community). They want dialogue, not just download links. One thing AI will never replace is the ability of a resident to sit down with a Councillor or Officer and walk away feeling heard and understood. Councillors expect transparency they can defend at the ballot box, Local Plans can result in the removal of an Administration. Inspectors expect to see that engagement genuinely shaped the plan.

In my experience early and repeated engagement on spatial strategy proposals help diffuse political flashpoints. In other cases tailored outreach to community groups improved participation from seldom-heard voices well above that Councils typical response rate.

Hertsmere Borough Council triggered over 6,000 responses by publishing its Green Belt options the week before Christmas in 2021. Timing matters more than templates — and local context matters even more.

What good looks like: five baseline tests for credible consultation

• Transparency: Be clear what’s up for discussion — and what isn’t. False hope fuels backlash. Don’t promise the world if your Local Plan review is limited to updates.

• Accessibility: Publish in multiple formats and languages (including sign language for presentations in-person and online, and easy read formats for documents and surveys). If people can’t understand it, they can’t engage.

• Responsiveness: Show where consultation has influenced change. Be up front on where things haven’t changed and explain why. Trackable feedback builds trust.

• Continuity: Keep engagement active between stages. Don’t disappear between Reg 18 and 19. You will squander the awareness and excitement you generate.

• Integrity: Treat consultation as collaboration, not persuasion. The difference shows. Timelines are tight, but local residents know their patch better than anyone and can often spot things that avoid causing issues later down the line.

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The average statutory consultation lasts six weeks (the legal requirement), but councils that extend to eight or ten often record double the participation rates — and fewer legal challenges later. This pattern has been observed in Planning Advisory Service (PAS) and Planning Resource surveys between 2022 and 2023, which found that extended consultation periods (8–10 weeks) typically achieved 1.7–2x higher response rates and fewer complaints or legal threats.

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Why it matters

Local Plans aren’t just policy documents, they’re democratic contracts (and I would argue the policy that eventually, knowingly or not, every resident will feel the impact of). When people feel shut out, opposition hardens. When they feel heard, scrutiny turns constructive. In an era of heightened political volatility, trust has become the currency of planning.

For councils, going beyond the statutory minimum isn’t a luxury, it’s risk management. For developers and partners, it’s the difference between delay and delivery.

Having sat on both sides of the table, as a former Councillor and as a consultant who’s led these processes in practice, I know that credible consultation pays dividends. It keeps plans sound, relationships intact, and communities engaged.

Final thought

Surrey’s reorganisation will test how governance reform affects planning delivery. But across England, the next wave of Local Plans will test something more fundamental: whether councils still see consultation as a box to tick, or a chance to lead. Larger and simplified councils should make that easier, right?

If your authority is preparing to consult, don’t just ask if you’re compliant, ask if you’re convincing.

Get in touch if you would like to speak about your Councils upcoming Local Plan consultation Send an email to rowan@coalfaceengagement.com

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Rowan Cole is Director of Coalface Engagement Ltd, Associate Director at Coverdale Barclay and leads Communications and Engagement for The Local Plan at the London Borough of Harrow. He has delivered Local Plan consultations and major engagement programmes for councils, developers and joint ventures across London, the South East, South West and beyond.

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