Guidance for commenting on the Local Plan

Guidance for commenting on the Local Plan

Use this guidance to help you when commenting on the final draft Local Plan.

If your comment seeks a change (or ‘modification’) to the plan:

  • You should clearly set out why you consider the plan is legally non-compliant or unsound, having regard to the soundness criteria (see Jargon Buster)
  • You should support your comment with necessary evidence and supporting information (where possible), as you may not have further opportunity to submit evidence after this point.  Any further submissions after this consultation may only be made if invited by the Inspector.
  • It will be helpful if you also say precisely how you think the plan should be modified.

If your comments represents the views of a group or individuals sharing a common view on the plan:

  • It will help the Inspector if you submit your comments as a single representation, rather than a large number of separate comments repeating the same points.
  • You should indicate how many people you represent and how your comments have been authorised alongside your response in the comment box provided.

If your comment seeks a change to the plan, you may wish to take part in hearing session(s):

  • Hearing session are part of the formal examination process, they will be held in public (normally at the Authority Headquarters) and give those who seek a change (or ‘modification’) to the plan a chance to make their case in person to the Inspector.
  • If your comment seeks a change to the plan, you may wish to take part in hearing session(s), and you should indicate this when submitting your comments now.
  • Only those who seek a change to the plan have a right to be heard at the hearing session(s).
  • Your decision to take part in hearing session(s) does not affect the weight of your comment(s).  Written and oral representations carry the same weight and will be given equal consideration in the examination process.

Jargon Buster - what we mean by:

Legal Compliance

To be legally compliant, the plan should:

Compliance with the Duty to Co-operate

Section 33A of the Planning and Compulsory Purchase Act (2004) requires us “to engage constructively, actively and on an ongoing basis” with neighbouring authorities and certain other bodies over strategic matters during the preparation of the plan, and provide evidence of this in a Statement of Common Ground published on our website.

Non-compliance with the duty to co-operate cannot be rectified after the submission of the plan. Therefore the Inspector has no power to recommend modifications to the plan in this regard. Where the duty has not been complied with, the Inspector cannot recommend adoption of the plan.


Paragraph 35 of the National Planning Policy Framework (2019) explains that a plan is sound if it is:

  • Positively prepared – providing a strategy which, as a minimum seeks to meet the area’s objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring authorities is accommodated where it is practical to do so and is consistent with achieving sustainable development;
  • Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
  • Effective - deliverable over the plan period and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
  • Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework (2019).

Important: if you think the content of the plan is not sound because it does not include a policy on a particular issue, you should go through the following steps before commenting:

  • Is the issue concerned already covered specifically by national planning policy?
  • Is the issue concerned already covered by another policy in this plan?
  • If the policy is not covered elsewhere, in what way is the plan unsound without the policy?
  • If the plan is unsound without the policy, what should the policy say?

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