At the pre-submission stage you need to link your comments to the tests of soundness. The NPPF identifies four tests against which the Local Plan will be assessed:
- Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
- Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
- Effective – the plan should be deliverable over its period and be based on effective joint working with adjoining local authorities and statutory consultees on cross-boundary strategic priorities; and
- Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
In order to make your comments effective you need to relate them to these tests. Here are some key tips on making comments:
- Clearly identify the policy or site proposal you are objecting to or supporting, using the reference number given in the plan;
- Say why you are objecting or supporting and, if you want to see a policy or site proposal changed, say how and put forward your own alternative wording and the reasons for it;
- Keep your comments as simple as possible and organise them in a logical order;
- Concentrate on the planning issues involved. These are known as material considerations.
- If objecting to certain aspects of a site proposal it is important to stress where you agree with the local authority so attention can focused on issues of conflict. Try to show that you have understood, yet still disagree with the local authority’s position;
- Referring to reliable published evidence to support your arguments can help to ensure that they are given more weight. Identify statements or analysis from the Sustainability Appraisal or other documents such as national policy, guidance or local technical studies which support your view;
- Refer to local issues and concerns, but try to relate them to the main planning issues. Your local knowledge is invaluable, but try not to get side-tracked onto non-material, temporary or non-planning issues. These include noise and disturbance during construction, and comments relating to property values and should be avoided.
- Your LPA will have a formal representation form, which you need to complete. Comments must be submitted in writing (either electronically or on paper).
- Local Plans seek to achieve a balance of different factors, e.g. enabling growth on the one hand, protecting valued landscapes on the other. It is particularly valuable to comment on whether you agree with the balance that has been struck and if there are any different approaches (for example different sites or strategies to locating development) that you feel would be more beneficial in planning terms.
Remember planning is here to serve the public interest. All planning documents are public documents and any comments you make on a planning document will be public information and will be able to be viewed by others.