1.2  This protocol takes into account the new arrangements provided by the Local Government Act 2000 and updates the original planning code. It is based on advice provided by the Local Government Association. (Probity in Planning Update – the role of councillors and officers, Local Government Association, 2002) and is an adjunct to the Code of Conduct.

1.3  The Protocol is intended as supplementary guidance for members and they are required to comply with the guidance and requirements therein. The Standards Committee has been authorised to take appropriate action and apply appropriate sanctions to any member who acts in breach of the Protocol.

2. The New Ethical Framework in Local Government

2.1 Part III of the Local Government Act 2000 introduced a new ethical framework for local government.

2.2 The Code of Conduct for Members, adopted by the Council on 28th February 2002, sets out expectations as to the conduct of elected and co-opted members of local authorities in the conduct of their official duties (and to some extent in their private life). Members are expected to comply with the spirit and not just the letter of their code.

2.3 The separation of private from public interests remains at the heart of the provisions, however, and to that extent, the new protocol does not represent any radical departure from the provisions and expectations of the former planning code. The ethical framework outlined above in most respects follows the recommendations of the Nolan Committee.

2.4 This planning protocol seeks to relate these requirements specifically to planning but goes beyond the probity concerns of the model and local codes to give more detailed advice on the operation of the system. The planning protocol therefore serves a dual role. Whilst the Code of Conduct is concerned primarily with individual probity and other aspects of conduct across the whole range of a councillor's duties, this protocol is concerned with the integrity of the planning system, including the conduct of councillors in its processes and procedures. The two documents overlap, but have different targets. Members are required by the Council to comply with these protocols and the Council has authorised the Standards Committee to take appropriate action and apply appropriate sanctions to any member who acts in breach of the protocols.

3. The Need for Guidance on the Conduct of Planning Matters

3.1 Planning is not an exact science. Rather it relies on informed judgement within a firm policy context. It is also highly contentious because its decisions affect the daily lives of everyone and the private lives of individuals, landowners and developers. This is heightened by the openness of the system (it actually invites public opinion before taking decisions) and the legal nature of development plans and decision notices. It is important, therefore, that the process is characterised by open and transparent decision-making.

3.2 One of the key purposes of the planning system is to control development in the public interest. In performing this role, planning necessarily affects land and property interests, particularly the financial value of landholdings and the quality of their settings. It is important, therefore, that planning authorities should make planning decisions affecting these interests openly, impartially, with sound judgement and for justifiable reasons. The process should leave no grounds for suggesting that a decision has been partial, biased or ill-founded.

3.3 Bearing in mind all these factors, it is not therefore surprising that from time to time things can go wrong unless councils are on their guard. In the past the volume and seriousness of public complaints have led to in-depth inquiries into a small number of councils. These inquiries revealed not only that certain matters were being conducted poorly, but that there was a very wide divergence of practice between councils. Doing things differently is not bad in itself, so long as what is done can be justified within a set of appropriate guidelines. This is where a local protocol can be very helpful.

3.4 This protocol applies to both councillors and officers who become involved in operating the planning system – it is not therefore restricted to just professional town planners and planning committee members.

4. The General Role and Conduct of Councillors and Officers

4.1 Councillors and officers have different but complimentary roles. Both serve the public but councillors are responsible to the council as a whole. Officers advise councillors and the council and carry out the council's work. They are employed by the council, not by individual councillors, and it follows that instructions may only be given to officers through a decision of the council or its executive or a committee. Any other system which develops is open to question. A successful relationship between councillors and officers can only be based upon mutual trust and understanding of each others positions. This relationship, and the trust which underpins it must never be abused or compromised.

4.2 Both councillors and officers are guided by codes of conduct. The statutory local code of conduct, supplemented by guidance from the Standards Board for England, provides standards and guidance for councillors. Employees will be subject to a statutory Employees' Code of Conduct. In addition, staff who are Chartered Town Planners are guided by the RTPI's Code of Professional Conduct, breaches of which may be subject to disciplinary action by the Institute. In addition, to these professional body codes, the Council's standing orders set down rules which govern the conduct of council business.

4.3 The Code of Conduct for Members sets out the requirements on councillors in relation to their conduct. It covers issues central to the preservation of an ethical approach to council business, including the need to register and declare interests (see section 5), but also appropriate relationships with other members, staff and the public, which will impact on the way in which councillors participate in the planning process. Of particular relevance to councillors serving on the Development Control and Environmental Protection Committee or Planning Committees is the requirement that a member:

4.4 The basis of the planning system is the consideration of private proposals against wider public interests. Much is often at stake in this process, and opposing views are often strongly held by those involved. Whilst councillors should take account of these views, they should not favour any person, company, group or locality, nor put themselves in a position where they appear to do so. Councillors who do not feel that they can act in this way should consider whether they are best suited to serve on the Borough Council's Development Control and Environmental Protection Committee or Planning Committee.

4.5 Councillors should also be very cautious about accepting gifts and hospitality, material benefits or advantage. The Code requires any members receiving any gift or hospitality, in their capacity as members, over the value of £25, to provide within 28 days of its receipt written notification of the details to the monitoring officer of the council. Such details will go in a register of gifts and hospitality, which will be open to inspection by the public. This requirement also applies to any offer of any gift, hospitality, material benefit or advantage whether or not the member accepts that offer. The best advice is for all gifts to be declined.

4.6 Similarly, during the course of carrying out their duties, officers may be offered hospitality from people with an interest in a planning proposal. Wherever possible, such offers should be declined politely. If the receipt of hospitality is unavoidable, officers should ensure that it is of the minimal level and declare its receipt as soon as possible. Officers are required to register any such hospitality as part of the Council's code of conduct for employees. However, members and officers should take care to ensure that they do not commit an offence contrary to the Prevention of Corruption Acts 1889-1916 when accepting any form of inducement.

4.7 Employees must always act impartially. In order to ensure that senior officers do so, the Local Government and Housing Act 1989 enables restrictions to be set on their outside activities, such as membership of political parties and serving on another council.

5. Members Interests

Registration of interests

5.1 The Local Government Act 2000 and the Code of Conduct place requirements on members on the registration and declaration of their interests and the consequences for the member's participation in consideration of an issue, in the light of those interests. These requirements must be followed scrupulously and councillors should review their situation regularly. Responsibility for fulfilling the requirements rests individually with each councillor.

5.2 A register of members' interests is maintained by the Council' s monitoring officer, which is available for public inspection. A member must provide the monitoring officer with written details of relevant interests within 28 days. Any changes to those interests must similarly be notified within 28 days of the member becoming aware of such changes.

Declaration of interests

5.3 The Code of Conduct abandons the use of the terms 'pecuniary' and 'non-pecuniary' interests. Instead it uses the terms 'personal' and 'prejudicial' interests. The code defines a personal interest in any matter under discussion as:

(1) if the matter relates to an interest in respect of which the member has given notice in the statutory register of members' interests; and

(2) if a decision upon it might reasonably be regarded as affecting to a greater extent than other council tax payers, ratepayers or inhabitants of the authority's area, the well-being or financial position of themselves, a relative or a friend, or

• any employment or business carried on by such persons;

• any person who employs or has appointed such persons, any firm in which they are a partner, or any company of which they are directors;

• any corporate body in which such persons have a beneficial interest in a class of securities exceeding the nominal value of £5,000; or

• any body which the member is required to register in the statutory register of interests, in which such persons hold a position of general control or management.

5.4 Where a member considers he has such a personal interest in a matter, he must always declare it, but it does not then necessarily follow that the personal interest debars the member from participation in the discussion.

5.6 The code will include some exceptions to this. For example, if the matter under discussion relates to:

• another authority of which the councillor is a member;

• another public authority in which the councillor has a position of general management or control;

• a body to which the councillor has been appointed or nominated as a representative of the authority.

Then, in these circumstances, the interest may not be regarded as prejudicial. In practice, therefore, the member would need to declare the interest, but could participate.

5.7 It can be seen that the provisions of the code are an attempt to separate out interests arising from the personal and private interests of the councillor and those arising from the councillor's wider public life. The emphasis is on a consideration of the status of the interest in each case by the councillor personally, and included in that judgement is a consideration of the perception of the public, acting reasonably and with knowledge of the facts. The Standards Board will from time to time provide guidance on code. In the end, however, the decision will be for the councillor alone to take.

5.8 Translated to a councillor's involvement in planning issues, the two stage test of personal the prejudicial interests will, as now, require a councillor to abstain from involvement in any issue the outcome of which might advantage, or disadvantage the personal interests of the councillor, his family, friends or employer.

5.9  If a member, in advance of the decision-making meeting had taken a firm view on the planning matter either in meetings of the other body or otherwise, they would not be able to demonstrate that, in participating in a decision, all the relevant facts and arguments had been taken into account – they would have fettered their discretion. Were they to participate in a decision in those circumstances, they might place their authority in danger of judicial review. This is also the general approach taken by this guidance on appropriate conduct in relation to membership of other bodies and the effects of such membership on participation in the planning decision-making process. It is expanded in section 7 on lobbying.

Councillors with prejudicial interests waiting to submit representations

5.10  Councillors who have a prejudicial interest in a planning application should not expect any representations they submit to the Planning Officer to be recorded in the Officer's report if they have made such representations in their official capacity.

5.11  Councillors with a prejudicial interest in a planning application are entitled to make representations thereon, in a private capacity as a member of the public but must not do so using Council headed papers or other facilities provided by the Council, including e-mail and personal computers.

5.12  Councillors may be asked by planning officers to seek advice from the Monitoring Officer about any possible prejudicial interests before discussing a case with a Planning Officer.

5.13  Councillors with prejudicial interests are not entitled to attend a Development Control and Environmental Protection Committee or the Planning Committee meeting for determination of the planning application in which they have a prejudicial interest, even where their representations made in a private capacity are summarised in the report.

A member in this category could however appoint an agent to attend for this item in accordance with the rules for public speaking on planning applications provided the agent is not another member of the Council.

5.14  Councillors who are dual hatted, ie those who serve on more than one relevant Authority and other public bodies when wishing to make representations on planning applications should refer to the guidance issued by the Standards Board for England entitled "Lobby Groups, Dual Hatted Members and the Code of Conduct". A copy of the booklet may be inspected in the office of the Monitoring Officer or viewed on the Standards Board for England website at www.standardsboard.co.uk.

Training/Seminars for Members Interests

5.15 Given the significance of well-informed and appropriate judgements by members on the declaration of interests, councils have been recommended to hold seminars at least annually on the issue, and the planning process generally. The Council does this through regular training seminars for members. The Standards Board nationally, and the Council's Standards Committee locally, have the statutory responsibility of promoting and maintaining high standards of conduct by members and assisting them to observe the authority 's statutory code of conduct. In providing such guidance and training to members at local level, the Standards Committee is required to highlight to members the need to comply with this protocol.

6. Relationship with Applicants, Agents and Objectors

6.1 With all applications, Councillors must consider whether or not any relationship that they may have with the applicant, or the applicant's agent, or an objector, or any other party having an interest in the application is such that members of the public knowing the facts of the situation would reasonably think that the relationship might influence the decision of the Councillor concerned. If so, the Councillor should declare an interest at the meeting when the application is considered.

6.2 Any officer who would otherwise be involved in the formulation of the recommendation must also adopt the approach set out above and must advise the Planning Services Manager or Director of Development Services immediately of that interest. In these circumstances, another officer will be instructed to deal with the matter.

6.3 Councillors may be asked by a constituent how to go about making a planning application, or how a particular proposal might be viewed. There is no harm in providing advice but the complexity of the planning process and policies could lead to the person misunderstanding the situation. Councillors should ensure that the person is advised to contact the relevant council officer dealing with planning matters.

7. Development proposals submitted by councillors and officers; and council development

7.1 Proposals to the Borough Council by serving and former councillors and officers and their close friends and relatives can easily give rise to suspicions of impropriety. So indeed can proposals for the Council's own development. Proposals can take the form of either planning applications or development plan proposals.

7.2 It is perfectly legitimate for such proposals to be submitted. However, it is vital to ensure that they are handled in such a way that gives no grounds for accusations of favouritism.

7.3 Serving Councillors who act as agents for people pursuing planning matters within the Council should play no part in the decision-making process for those proposals. Similarly, should they submit their own proposal to the Council, they should play no part in its processing.

7.4 Any applicant or agent who is a serving Councillor or an officer of the Council should make it clear at the time of submission of the planning application that this is the case and the Planning Services Manager will keep a separate record of such applications.

7.5 An application made by a Councillor or officer where notice has been given will be determined by the Development Control and Environmental Protection Committee or the Planning Committee and not by officers under delegated powers.

7.6 Proposals for a Council's own development will be treated in the same way as those of private developers, in accordance with DoE Circular 19/92.

7.7 The consideration of a proposal (either a planning application or a development plan proposal) from a councillor would be considered as a prejudicial interest under the Code of Conduct and as such, the councillor would be required to withdraw from any consideration of the matter. The code also provides that the councillor should 'not seek improperly to influence a decision about the matter'. It is important to emphasise here that 'improperly' does not imply that a councillor should have any less rights than a member of the public in seeking to explain and justify their proposal to an officer in advance of consideration by a committee. If a councillor wishes to speak against the Council' s position at a local inquiry for personal reasons, he or she should make the position clear at the outset.

8.1 It is important to recognise that lobbying is a normal and perfectly proper part of the political process: those who may be affected by a planning decision will often seek to influence it through an approach to their elected ward member or to a member of the Development Control and Environmental Protection Committee or the Planning Committee. As the Nolan Committee's third report states: "It is essential for the proper operation of the planning system that local concerns are adequately ventilated. The most effective and suitable way that this can be done is through the local elected representatives, the councillors themselves" (paragraph 288). Any protocol failing to take account of the realities of the political/representative process will not carry credibility with experienced elected members.

8.2 However, such lobbying can lead, unless care and common sense is exercised by all the parties involved, to the impartiality and integrity of a councillor being called into question. When being lobbied, councillors, and members of the Development Control and Environmental Protection Committee or the Planning Committee in particular, should take care about expressing an opinion that may be taken as indicating that they have already made up their mind on the issue before they have been exposed to all the evidence and arguments. In such situations, they should restrict themselves to giving procedural advice, including suggesting to those who are lobbying, that they should speak or write to the relevant officer, in order that their opinions can be included in the officer's report to the committee. If they do express an opinion they should make it clear that they will only be in a position to take a final decision after having heard all the relevant evidence and arguments at committee.

8.3 It should be remembered that reports on poor practices within local authorities are greatly concerned with the issue of lobbying. In a number of cases, lobbying has caused considerable public mistrust of the councils.

8.4 Councillors, and members of the Development Control and Environmental Protection Committee or the Planning Committee in particular, need to take account of the general public's (and the Ombudsman's) expectation that a planning application will be processed and determined in an open and fair manner, in which members taking the decision will take account of all the evidence presented before arriving at a decision, and that to commit themselves one way or another before hearing all the arguments makes them vulnerable to an accusation of partiality. It is probably misleading to describe the determination of a planning application strictly as a 'quasi-judicial' process (unlike, say, certain licensing functions carried out by the local authority).

It is, nevertheless, a formal administrative process involving rules of procedure, rights of appeal and an expectation that people will act reasonably and fairly. There is an added possibility that an aggrieved party may seek judicial review on the way in which a decision has been arrived at; or to complain to the Local Government Ombudsman on grounds of maladministration; or to the Standards Board for England that a member has breached the Code of Conduct.

8.5 In reality, of course, members will often form a judgement about an application early on in its passage through the system, whether or not they have been lobbied. The difficulty created by the nature of the committee's proceedings as set out in the paragraph above, is that members of the committee (at least those who are not councillors of the affected ward) should not openly declare which way they intend to vote in advance of the planning meeting, and of hearing evidence and arguments on both sides.

8.6 It is important to distinguish between the role of the Development Control and Environmental Protection Committee or the Planning Committee member and the role of ward member whose ward is affected by a particular planning application. A committee member who does not represent the ward affected is in an easier position to adopt an impartial stance, however strong his or her feelings about the application may be, and to wait until the committee meeting before declaring one way or another.

8.7 A Development Control and Environmental Protection Committee member is in a difficult position if it is a controversial matter around which a lot of lobbying takes place. If a member responds to lobbying by deciding to go public in support of a particular outcome – or even campaigning actively for it – it will be very difficult for that member to argue convincingly, when the committee comes to take a decision on the application, that he or she has carefully weighed the arguments presented. The proper course of action for such a member would be to make an open declaration and not vote.*

8.8 In such circumstances, the member concerned will be permitted in declaring their interest to make a statement prior to debate on the proposal by the Committee but thereafter to take no further part in the debate and withdraw from the room.*

8.9 Given that the point at which a decision on a planning application is made cannot occur before the committee meeting, when all available information is to hand, and has been duly considered, any political group meeting prior to the committee meeting should not be used to decide how councillors should vote. The view of the ombudsman in relation to the former national code was that the use of political whips to seek to influence the outcome of a planning application could amount to maladministration. There is nothing in the Model Code which would serve to change this advice.

8.10 With the exception in some circumstances of ward councillors, whose position has already been covered in the preceding paragraphs, councillors should in general avoid organising support for or against a planning application and avoid lobbying other councillors. Such actions can easily be misunderstood by parties to the application and to the general public.

8.11 Councillors should not put improper pressure on officers for a particular recommendation, and, as required by the Code of Conduct, should not do anything which compromises, or is likely to compromise, their impartiality.

8.12 Councillors who are unsure as to whether an interest should be declared should seek the advice of the Council's Monitoring Officer, although, as indicated above, the decision rests with the councillor.

9. Pre-application Discussions

9.1 Discussions between potential applicants and the officers are positively encouraged. The purpose of the discussions is to ensure that applicants can have an understanding of the Council's planning policies and local matters that might be material to the application in order that when the application is submitted it contains all the necessary information so that the application can be processed speedily. Discussions can also discourage applications being submitted which are unlikely to be approved in principle.

9.2 However, pre-application discussions are undertaken on the basis that they cannot bind the Council into making a particular decision. Any views expressed are personal and provisional. By the very nature of such meetings not all relevant information will be to hand and neither will formal consultations have been carried out with interested parties.

9.3 Advice given at meetings will be based upon the development plan and material considerations which appear relevant to the application.

9.4 A written note is kept of all potentially contentious meetings or telephone discussions with the developer or agent.

10. Officer Reports to Committee

10.1 Reports to committee are intended to be accurate and objective and include all matters relevant to the application.

10.2 Reports will include an explanation of relevant development plan policies, the site history, a description of the site and any other considerations. Reports will include the substance of objections and views of people making representations and also those of organisations who have been consulted on the application. Any late objections received after the agenda has been published will be reported in writing on the day of the meeting. Only very late comments will be presented orally.

10.3 All reports on applications will contain a written recommendation. In the event of a significant amendment by the applicant/agent being received after the publication of the report that is fundamental to the recommendation and will necessitate re-notification of neighbours, then these amendments be not accepted.

11. Correspondence Received by Councillors

11.1 The Council's Constitution requires any Councillor who receives correspondence relating to an application for planning permission, listed building consent or similar to provide the Director of Development Services (in practice, the Planning Services Manager) with a copy of the correspondence as soon as conveniently possible. Details of such correspondence are included within the agenda papers for the Committee or in the list of late letters produced for the Committee.

12. Public Speaking at Committee

12.1 The Council provides the opportunity for public question time at all its committees and a leaflet is available to explain how the procedure operates.

12.2 There are also special arrangements for public speaking at the Development Control Committee and Environmental Protection Committee and the Planning Committee on applications. The purpose of the right to speak is to give members of the public the opportunity to make their views known directly to the committee about the planning merits of individual planning applications. The right to speak applies equally to objectors, supporters, and Parish Councils. Applicants or their agents have the right to speak only in response to an objector speaking at the meeting. A leaflet is available providing further advice on public speaking on planning applications.

13. Decisions contrary to officer recommendations and/or the development plan

13.1 The law requires that where the development plan is relevant, decisions should be taken in accordance with it, unless material considerations indicate otherwise. (s.54 A Town and Country Planning Act 1990).

13.2 This gives rise to two main issues: first, all applications which are not in accordance with the development plan must be identified as soon as possible. They must then be advertised as such, as required by Article 8 of the Town and Country Planning (General Development Procedure) Order 1995. Second, if it is intended to approve such an application, the material considerations leading to this conclusion must be clearly identified, and how these considerations justify overriding the development plan clearly demonstrated. The application may then have to be referred to the relevant Secretary of State, depending upon the type and scale of the development proposed. If the officers' report recommends approval of such a departure, the justification for this is included, in the report.

13.3 If the Development Control and Environmental Protection Committee or the Planning Committee makes a decision contrary to the officers' recommendation (whether for approval or refusal), a detailed minute of the committee's reasons is made. The officer should also be given an opportunity to explain the implications of the contrary decision at the meeting. The courts have expressed the view that such reason should be clear and convincing. The personal circumstances of an applicant will rarely provide such grounds.

13.4 Where the Development Control and Environmental Protection Committee or the Planning Committee are minded to refuse an application contrary to the officers advice, the Committee will fully specify the grounds for refusal; these grounds are considered by the Senior Solicitor and the Planning Services Manager in respect of their lawfulness and sustainability; and, if none of the grounds are considered to be lawful and sustainable the application will be referred back for determination to the next meeting of the Committee.

13.5 The Development Control and Environmental Protection Committee will refer to the Planning Committee for determination any proposed refusal of deemed planning permission or the reference back to the Cabinet of a decision to seek planning permission; any application which the Committee is minded to approve which, if approval, would result in a significant departure from the policies of the development plan; or any controversial application that the Committee fails to determine. The reason for determining any application for planning permission which is a significant departure will be minuted.

13.6 A senior legal officer always attends the meeting to ensure that procedures have been properly followed. Whilst the Council makes extensive use of standard wordings for conditions, in the case of any conditions which councillors may wish to add to or amend, officers have delegated powers to draft such conditions which need to be reasonable and relevant to the permission.

14. Committee Site Visits

14.1 Visits to application sites by the Development Control and Environmental Protection Committee or the Planning Committee are only likely to be necessary when the proposed development is difficult to visualise from plans, where there is good reason why the comments of the applicant and objectors cannot be adequately expressed in writing, or, where a proposal is particularly contentious.

14.2 Site visits take place on the day of Committee following a schedule agreed by the Chairman which takes account of any members requests. Members should bear in mind that a site visit should only be held where the expected benefit is substantial. The Audit Commission have criticised councils who undertake unnecessary site visits.

14.3 Site visits consist simply of inspecting the site to assist members to appreciate relevant land use issues of the proposal. Members should not engage in discussion with the applicant, agent or objectors on the merits of the application if they are present, nor express a view on the proposal on the site. The discussion of the merits of the application and the decision takes place at the meeting, not at the site visit.

15. Conduct at Meetings

15.1 The conduct of any meeting where a planning application is considered is the overall responsibility of the chairman of that meeting. If the Chairman believes that a member is not observing the rules regarding declaration of interest, then he may have to take action to ensure that Standing Orders are not breached. In addition, individual councillors and officers have a responsibility for their own conduct and should not operate in such a way as to cause anyone present to think an application has not been treated properly.

15.2 The determination of applications by the Development Control and Environmental Protection Committee or Planning Committee is part of a formal administrative process and opinions and comments of Members should be restricted to the relevant planning merits or otherwise of the application.

15.3 The Committee may, very occasionally, determine that an item on the agenda relates to an exempt matter under Schedule 12A of the Local Government Act 1972 which requires the exclusion of the public from the meeting. It is unlikely that this would ever relate to the determination of a planning application but could relate to an enforcement matter or when legal advice is being given.

16. Regular review of decisions

16.1 The report of the Audit Commission entitled "Building in Quality" recommended that councillors should revisit a sample of implemented planning permissions to assess the quality of the decisions. Such a review should improve the quality and consistency of decision-making, thereby strengthening public confidence in the planning system, and can help with reviews of planning policy.

16.2 Such reviews have been undertaken in the past and are best undertaken at least annually. They can include examples from a broad range of categories such as major and minor development, listed building works and enforcement cases. The Development Control and Environmental Protection Committee, Planning Committee and the Planning and Environment Overview and Scrutiny Committee could be involved in the review and decide whether it gives rise to the need to reconsider any policies or practices.

17. Complaints

17.1 The nature of planning is such that many decisions are contentious and some people can remain dissatisfied with the outcome of an application.

17.2 Despite taking care in processing applications and making decisions, complaints are made but it is hoped that the adoption of this protocol will greatly reduce occasions on which a complaint may be justified.

17.3 The Council has its own complaints system and if a complainant is dissatisfied with the outcome following the investigation of a complaint, there is a further opportunity of lodging a complaint with the Local Government Ombudsman.

17.4 Every planning application file contains an accurate record of events throughout its life. It should be possible for someone not involved in the application to understand why the decision was and how and why it was reached. Where decisions are taken under the officers' delegated powers, these decisions are also accurately recorded and documented.

17.5 Whatever procedures a council operates, it is likely that complaints will be made. However, the adoption of the advice in this guidance should greatly reduce the occasions on which complaints are justified. It should also provide less reason for people to complain in the first place.