10 tips for responding to development plan consultations to ensure your voice is heard.
Local planning authority development plans, known as ‘local plans’ in England and ‘local development plans’ in the rest of the UK, are an important part of the planning system. It’s really worthwhile getting involved in development plan public consultations when yours is being reviewed or renewed. By getting involved, you can speak up for nature and ensure that new development takes account of local wildlife interests.
These plans can allocate strategic sites for development, establishing a principle in favour of planning permission being granted on those sites. They can also contain positive policies that support the protection and enhancement of biodiversity, such as requiring certain new developments to incorporate wildlife and climate friendly features.
Here are 10 simple tips to help maximise the effectiveness of your engagement. Many of these tips can also be applied to other types of plans where there is a public consultation process.
Ideally you should try to respond at each consultation stage (there are usually at least two stages for new development plans) but missing an earlier stage doesn’t prevent you from submitting comments at later stages. You will however be able to have more influence earlier on in the process, with different policy options often presented at the first stage. As the consultation process continues and the new draft plan develops, the grounds on which you can comment also become more and more restricted.
Get involved at the local plan stage when sites are considered and decided, it may be too late once it’s in the plan and planning permission is sought” -Mel, Chippenham, local nature champion
Numbers do matter, so coordinating your comments with others who share your concerns or ideas about particular policies can be very effective. The group might be opposed to a proposal to allocate a specific site for housing or other development. Or you may want to advocate for stronger policies to support local nature, such as requiring new developments to include Swift nest bricks. If everybody in your group sticks to the same or similar message, it will help ensure your voice is heard more clearly by the plan-maker.
Development plans include a lot of different policies and other information for the area they cover, but you don’t have to comment on everything. Just respond to the parts that you want to change or support. However, do try to think about connections to other parts of the plan. For example, a proposed allocation for new development that you believe will impact on important local wildlife may also conflict with other policies in the draft plan that aim to protect and restore nature. Pointing out such inconsistencies can help influence changes.
You don’t need to live in the area that a development plan covers to be able to engage in a public consultation on it. You will usually be asked to fill out your name, address and other details for monitoring purposes, but your comments should still have the same weight as that of any local residents.
You don’t have to answer the consultation questions, but forming your comments around any relevant questions can help ensure your comments are within scope (or, in other words, relevant) at that stage in the process. Comments that are deemed to be outside of the scope of the plan, or not relevant at that particular stage of the consultation process, may not be considered ‘duly made’ and therefore may not be taken into consideration. Answering the consultation questions can help ensure you are focusing on the right issues that are open for discussion.
As the saying goes ‘the devil is in the detail’ and you may find important pieces of information in other technical documents, such as a Sustainability Appraisal or (where internationally important wildlife sites are present) a Habitats Regulations Assessment. Make sure you highlight any errors, inconsistencies, or omissions in these documents where they relate to your issues of concern.
It’s really helpful if you can show that your concerns are supported by guidance (eg government or government agency guidelines), legislation or other higher tier policies, such as national planning policies. Be as specific as possible by clearly referencing and even quoting short sections of text from such policies, guidance or legislation where you feel they help to support your case.
As with planning applications, comments that are supported by clear and robust reasoning and, where possible, objective evidence will usually have greater effect. Including positive examples from other development plans can also really help to make your case.
Perhaps the only way to address your concerns would be to remove a proposed allocation or other policy. But think about whether other smaller changes to the plan could help. For example, adding a requirement to an allocation policy for a specific type of mitigation to be provided might be enough to protect the wildlife interests you’re concerned about.
Think about where there is potential for compromise, and when you have to go "all out".” -Local nature champion
Don’t assume that because you raised a point early on in the consultation process that the job is done! Keep checking the further stages of the plan’s development to see if your concerns have been addressed; you may need to continue to make your points if the issues remain. And remember that you must respond to the final stage of the development plan consultation if you want to take part in the examination process. This part of the process will allow you to raise your concerns with an independent assessor appointed by the Government to test the plan for ‘soundness’.
Take a look at our country guides to local plans/local development plans in the Find out more links below, for more information about the examination process and any country differences in the approach to plan consultation and examination (eg in Northern Ireland, the local development plan is formed of two parts, each with its own consultation and examination).
If you have the funds available, employing a planning, ecology or other technical specialist to support you through the process can be really valuable. But if you don’t have the budget for this type of help, there may be some free advice available to you, including from other individuals or groups that are willing to share their own experiences. Take a look at our Resources for advice services or other possible support available in your area.
You should be able to sign up for email updates on your local plan/local development plan via your local authority’s website. There should also be notifications of any public consultations in local community newsletters. Find your local development plan-making authority here.
England – Your local plan: what is it and when can you get involved?
Scotland – Your local development plan: what is it and when can you get involved?
Wales – Your local development plan: what is it and when can you get involved?
Northern Ireland – Your local development plan: what is it and when can you get involved?
