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This repoert is the subject of a motion to
be put before Hounslow Council's Sustainable Development Committee on Wednesday 17 February 2010
A REPORT ON THE IMPLEMENTATION OF THE ELECTRONIC
DOCUMENT MANAGEMENT SYSTEM (EDMS) AT THE LONDON BOROUGH OF HOUNSLOW’S PLANNING DEPARTMENT
Since the implementation of the Electronic Document Management
System in the Planning department of the London Borough of Hounslow (EDMS) residents (both as individuals and in the form
of Amenity Groups), and their elected representatives, have continually voiced concerns about the shortcomings of the system.
They have done this not because they are Luddites attached to a 19th Century way of working but because they want
the system to be a genuine improvement, a real leap into the 21st century rather than merely using modern
methods to achieve a retrograde step. They believe that it is fundamental that any electronic
planning document system should exceed the benchmark of the old paper system. However, even though they
have patiently and positively raised concerns and suggested improvements with regard to the following:
- Accessibility
- Usability
- Process and Communication
- Consultation
- Reliability
- Resilience and Sustainability
Improve
the current planning system and ensure its integrity.
To fully meet the
Council’s high aspirations for community engagement and participation.
1.0 THE
MEASURES
1.1 A schedule for the implementation of these measures should be formulated
and circulated to all Sustainable Development Committee (SDC) members within two weeks of the next meeting. This
schedule will be discussed and ratified at the SDC meeting on the 17th March but this should not prohibit the implementation
of any of the measures until then. A progress report of what measures have been achieved is to be presented at that meeting.
1.2
A senior officer
with the requisite over-arching authority should be nominated with a special responsibility to co-ordinate the work and to
ensure the schedule is maintained. This officer is to be identified in the schedule sent out to SDC members.
1.3
A special scrutiny panel should be set up to cover
(but not be limited to) monitoring the implementation of these measures, as well as the council’s Community Engagement
policy. It is recommended that in addition to Overview & Scrutiny Committee (OSC) members, the panel
consists of:
- SDC Members who wish to serve on it and
- co-opted members of local
amenity groups who have demonstrated a sustained interest in planning matters over a period of time.
1.4 It is also recommended that
groups or individuals that are not thus represented be interviewed about their experience(s) of the current system. Many people
who need to access the planning system might only do so on a one-off basis which means they might not have the skill-set developed
by more sustained users over a period of years. Since an electronic management system of planning materials should aim to
be as accessible to the infrequent user as much as the frequent user, their testimony should be considered fully.
1.5 It is recommended that the scrutiny
panel makes interim reports to every other SDC meeting starting in June and continue to do so until it has reached its final
conclusion, and that these reports are also made available to Area Committees throughout the process.
2.0 DEFINING THE TERMS OF THE ELECTRONIC DOCUMENT MANAGEMENT
SYSTEM (EDMS)
2.1
It has not been made clear in layman’s terms what the Planning EDMS
is or what it is supposed to achieve and therefore it has been impossible to quantify success. Even officers using the system
have been unable to give a clear definition of what it is. A definition avoiding technical jargon wherever
possible should be published immediately as to what EDMS is and what it is supposed to achieve.
2.2 It
is not certain if there was a coherent benchmarking exercise against other equivalent Boroughs prior to the introduction of
the current EDMS. If this was carried out then the results of that exercise should be published and independently
evaluated. Shortcomings of the benchmarking exercise should be rectified immediately.
2.3 If this was not carried out then it should be instigated immediately and results contained within the
report to SDC in March 2010.
3.0
ACCESSIBILITY AND USEABILITY
3.1 For All Applications:
It is understood that putting services on-line has enormous benefit for people with mobility problems.
However, at Hounslow’s Disability Community Forum (DCF), people who are visually-challenged expressed dismay
at the channel-shift and feared they would be excluded once paper copies are phased out. It is not
clear if an Equalities Impact Assessment (EIA) was carried out. If it has then it should be made available to SDC Members
for their perusal. If not, this should be done as a matter of urgency.
3.2 Ease of Access to data/information should be the fundamental
principle underlying any EDMS for the management of planning work. A measure of the effectiveness of EDMS
might be how the officers use the system. At present there is little evidence that officers have migrated to the new system
wholesale, in fact the evidence is still to the contrary with officers relying on paper plans and documents. An
independent evaluation should be carried out with regard to ease of use as a matter of urgency and the results communicated
to SDC.
3.3
We believe that one indication that the system is effective would be the ability
of officers to conduct the business of a planning meeting relying solely on what can be retrieved electronically from the
council’s planning website.
A target date should be set for this to be achieved.
3.4 One of the goals
of any IT system should be an intuitive ease of use. The current system has a considerable journey to travel
before it gets anywhere close to this, especially when considering the broad spectrum of ability and IT literacy of potential
users it is meant to serve. To enable greater accessibility, a simple ‘How to…?’ guide,
that can be down-loaded with ease, should be written and road-tested on a selection of people with a wide range of skills
and posted in a prominent position on the Planning homepage. We would also like copies to be e-mailed to
amenity groups that are currently on the Council’s register.
3.5
Information is only useful if one knows it is there. While all planning information is apparently on the website it
is not much use if it is not properly ordered and adequately indexed. We ask that, with immediate effect,
all ‘live’ applications are given an index of the contents and be checked that the documents are in the proper
order.
3.6 Searching
for specific drawings on-line within a planning application is currently difficult since generic terms such as ‘drawings’
or ‘plans’ are used rather than specific descriptions. It makes sense that, in future, the actual drawing
title is to be used on the file label and in the contents list. When the drawings are arranged in
multi-page drawing sets, each drawing should be saved and labelled as a separate document.
3.7 At the moment a number of drawings are simply inaccessible
and the message gives no contact phone
number. Where the paper drawings are too large or are inaccessible for some other reason, a working link
should be provided that will automatically generate a request for a paper copy of the drawing.
3.9
A plan without a scale is not much use at all. On-screen scaling software ought
to be provided for use with all applications. It would be prudent to evaluate this software before deployment
to ensure that it is accessible for all users. It is recommended that members of the DCF are invited to
assist with this evaluation.
3.10 Currently, when plans change,
the old plans are deleted from EDMS, meaning that interested parties cannot compare previous plans with the current ones.
In other Boroughs this is not done and plans are available for comparison. In the interests of all,
old plans must be available for comparison from now on and there should be a link between the current plans and the old ones.
3.11 When
EDMS was first mooted in reports to Area Committees it was said that libraries would have large screens to aid the perusal
of plans. However, it transpired that Libraries had no plans (or budget) to install large screens in any of their facilities.
A feasibility study (having due regard to the EIA) should be carried out regarding the installation of large
screens, and printers available to the public, for the viewing and printing of planning documents at the Civic Centre and
at every library in the borough. Such a study should include an assessment of having a capability to allow
the printing of all applications at libraries within a reasonable time frame, e.g. two working days, once a request has been
submitted. 3.12
Design and Access statements are principally aimed at helping councillors to evaluate applications.
If reproducing these in some cases is too expensive councillors should have access to large screens at the Civic Centre to
read the documents properly.
3.13 Major Applications
Until such time as these facilities are installed all
applicants for: - Major
applications including, but not limited to, those going to SDC
- Significant
‘follow-on’ applications from aforementioned majors
- Applications within Conservation areas
- Advertisement proposals
- Applications in respect to listed buildings should continue to be advised that they should include hard copies
of all the documents for the Civic Centre, all libraries and nominated amenity groups within that area.
3.15 Local amenity
groups within the appropriate area appreciate the case officers sending an e-mail confirming their receipt of these. We ask
that this should be made standard practice.
3.16 This whole process should not be phased out until there is an evaluation
carried out that demonstrates to SDC that these are no longer required.
3.17
Since access to major applications, in meaningful terms, will continue via libraries we
ask that opening hours be reviewed with the intention of extending these to cover the hours when members of the public usually
access planning documents, i.e. evenings and weekends. Although it is acknowledged that current library
hours give increased access over the previous method to both major application documents and on-line access to minor applications
for those without a home-computer, these not adequate for a council that regards community engagement as a fundamental principle
underpinning all of its activities.
4.0 PROCESS AND COMMUNICATION
4.1 We recommend that the automatic electronic
acknowledgement of e-mails sent to the Planning Department via planningcomments@hounslow.gov.uk should indicate which plans one has commented
on as well as a copy of those comments so that residents have a complete record of their submission.
4.2
Currently, responses to letters are not being published on-line. This means that the planning process is not as clear
and transparent as it could be. We recommend that in future, responses to letters, including internal memoranda,
should be accessible on the planning website within the case file to ensure transparency of the process.
4.3
Currently, weekly lists are kept on-line for only 5 weeks. This seems an incredibly short and arbitrary time and possibly
vestigial from when memory space was more critical. One of the claims for having an EDMS is
that it reduces physical storage of documents so there does not seem to be any valid reason for not keeping them longer.
Surely there can be no objection to the weekly lists remaining accessible for the life of the planning application.
4.4
Amenity groups appreciate it when officers send them an e-mail alerting them to an application that they might be interested
in, and again, we feel this should become the norm.
5.0
CONSULTATION AND ENGAGEMENT
5.1
We believe that there is a register of local amenity groups who express an interest in planning issues or who might
be considered to have an interest in a particular planning matter within the planning department. We ask that this register
is reviewed, cleansed and updated annually and that a copy of this list is e-mailed to relevant members following this process.
5.2
The system is not much use if the website is down. The council’s website has been frequently inaccessible recently
(possibly due to the mammoth upgrading that the IT department is currently carrying out), especially at weekends, 6th
and 7th February being a case in point. As this is when many residents who work during the week
will favour trying to access it we ask that, should EDMS fail within a consultation period, and documents are not available
through reasonable alternate means, then the consultation period should be extended for a commensurate period to off-set the
loss of access. In other words, consideration should be given regarding the day and time the system went
down, and if this is in one of the peak-traffic periods, then the consultation period should be extended to cover this period.
The loss of a weekend should be replaced by another weekend rather than just two extra days tacked on to the end of the consultation
period (if correspondence is received after the end of the consultation period it should still be considered as now if at
all possible). 5.3
It should be noted that members of the public have been frustrated with a lack of a proper
response to their legitimate questions and concerns on planning issues. A simple question as to why multiple
letters were sent to an individual at the same address took many months to achieve a proper answer which was actually quite
simple. It highlighted the fact that the essential problem was insufficiently regular database cleansing. Having
heard the answer Members were able to suggest a variety of solutions to the problem that should have been implemented with
immediate effect. It needs to be made clear that, with immediate effect, residents’ questions should be responded to
in a reasonable time and in a meaningful way. Openness and honesty is the key. It must be made clear that,
if an officer does not immediately know the answer, it is not acceptable to fob a resident or a Councillor off with vague
responses such as ‘Health and Safety’ or ‘Data Protection Act’ or ‘technical reasons’.
It is acceptable for officers to say that they do not immediately know the answer but that they will find
out and then come back to the enquirer within a reasonable time.
5.4 We strongly recommend that officers at all levels are to given a proper understanding as to their role
in community engagement. We strongly recommend that an evaluation as to how they are complying with this
policy should form part of their Professional Development Assessment. As part of the training it is recommended
that there should be a workshop with local amenity groups so as to get a better understanding of their needs and officers
should be issued with a digest of their responsibilities with regards community engagement as it now stands.
6.0 RESILIENCE
6.1
A review should be carried out of the proposal not to retain paper copies
of applications. The longevity and resilience of digital storage must be established beyond doubt and the
evidence for this presented to a panel of Members before the proposal to dispose of paper copies once they have been entered
into the database is allowed to proceed. In the meantime the current arrangements for the physical storage
and security of digital records should be reported to SDC at the March 2010 meeting.
6.2 Similarly,
a view should be presented to the same panel, again supported by indisputable evidence regarding the security of documents,
against subsequent fraudulent changes being made and again the panel must be satisfied that the risk is negligible before
the proposal is allowed to proceed.
7.0 SUSTAINABILITY
7.1 No system
is sustainable if the officers charged with running it do not have the requisite training to do so. It
has been established that there is no data-basing capacity in the planning department which suggests that IT training in this
department is slender. We urge an immediate needs-assessment is done and that this is translated into action
in the form of proper training to equip officers with the requisite IT skills to function in a modern planning environment.
7.2 Similarly we urge that library staff is also given requisite
training to assist all those accessing planning documents and this should be recognised as part of their operational duties.
8.0
Conclusion
8.1
It may be that some of these measures have been implemented already as a result of discussions elsewhere. In the event
of this, and for the sake of congruency, these should be retained within the proposed measures but identified as having been
already fulfilled.
REPORT COMPILED BY:
Rosemary
Bunce for the Four Roads Residents Association
Andrew Dakers for Hounslow Liberal Democrats
Christine Diwell for the Isleworth Society
Jon Hardy for the Independent Community Group
Chris Hern, Town Planner
David Pavett,
IT professional
Matthew Rockel for Brentford Community Council
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