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Observations on Consultation Drafts, PPS 12 And Guide to LDF Preparation
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- 4.4.2 - We have several points here, as follows -
- Just what would be published for representations? The text currently refers to the representations received which propose alternative sites, but these representations could be numerous and lengthy, so is it really intended that they are published in full? Surely a summary would suffice.
- How would publication take place?
- For how long?
- How long would people have to comment?
- 4.4.3 - The first sentence of this paragraph belongs before para 4.4.2. What does the word "immediately" mean in the final sentence? Reflection will show that it is impossible to publish immediately, given that some representations will be received on the last day of the representation period. If a summary is to be used, that of itself will take some time to prepare. We trust that such language will not appear in Regulations.
- 4.4.8 - There should be explicit reference to the community strategy under the first bullet point.
- 4.5.1 - We have three matters to raise here -
- Given that the Inspector's report will be binding, surely he or she will set out conclusions, not recommendations, because there is will be nobody to make recommendations to. The language of Section E of the Code of Practice is more appropriate.
- But there is a bigger point here, about the Inspector producing a definitive report which resolves the plan. The advice about not bringing forward new material to the examination is a key issue of practice for the planning authority, and ought to be brought out in the section we seek on the key principles of the new system and consequent implications for practice.
- As for other parties, the advice ought to be framed quite differently, to say that since the plan will have begun to "set" following the consultation on options, new material only introduced at the inquiry will only carry limited weight with the Inspector. This needs to carry over into the Code of Practice.
- 4.7.3 - You will already have spotted the erroneous reference to the "development plan document" here.
- Appendix A, 2.1.2 - Green Belts are not designated nationally.
- Appendix A, 2.1.6 - The reference to "all lines" is not clear. Should this not be something like "all notations"?
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