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Observations on Consultation Drafts, PPS 12 And Guide to LDF Preparation

Author: Andrew Wright | General Manager, POS Enterprises Ltd
Date: 08-01-2004
Email: andrewwright@posenterprises.co.uk

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THE GUIDE TO PROCEDURES AND CODE OF PRACTICE

  1. Overall - The same point applies here as to the draft PPS about setting out the principles of the new system, the key implications for practice, and chronological treatment of the various elements as an aid to understanding.

  2. 1.8 - It is important to make it clear here that where the planning authority prepares several DPDs alongside each other, the usual practice will be to have an integrated examination process, rather than several separate examinations in front of different Inspectors.  This also needs to be covered in Section D of the Code of Practice.

  3. 1.11, Section 2, and Section B of the Code of Practice - We have to take issue with the language here.  Continuous community involvement is impossible and therefore misleading- we have to do other things in between!  We suggest "ongoing" or similar language to convey the message that engagement will not just be a one-off process.

  4. 2.5 - This is confusing.

  5. A.2 - The reference to a pre-submission stage is not relevant to an SPD.

  6. Diagram following B.1 - The same comments apply here as to the diagram showing the DPD process.

  7. B.10 and C.17 - the third bullet point in each case should be amended to refer to the objector's view that the SCI or DPD fails the test of soundness.

  8. B.14 - It appears that some words have gone missing after "…consider the soundness of the statement of community involvement".

  9. C.6 to C.8 - This does not sit happily here, since it deals with the time before submission, while the following text is to do with the earlier stage of consultation on preferred options.  It would be better later.

  10. C.10 - The third sentence is not clear.

  11. C.11 - This glosses over the fact that the Inspector will need to consider the SA/SEA implications of any changes he/she is minded to make in finalising the plan.

  12. Section D - See our comment on paragraph 1.8 of the Guide to Procedures.


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RELATED ARTICLES
Observations on the Consultation Draft of PPS 11
08-01-2004
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