Model Representation Form for Local Development Plans

Pembrokeshire County Council’s
Deposit Local Development Plan Response Form
PART 1: Contact details
Your contact details
Your Agent’s contact details
(where relevant)
Title:
Name:
Organisation:
(where relevant)
Address:
Postcode:
Telephone no:
Email:
Preferred method
of contact:
(Email / Post)
Language
preference:
(Welsh / English)
Office Use Only
Representor Number
………………………….
Submission Type
(Via Swift online, Email, Post, etc)
………………………….
1
PART 2: Responding to the Plan
You should include all your responses on an official Response Form (this form).
Please use separate forms for representations that object to the plan as opposed to
those that support the plan. If you are submitting the form electronically, the form is
designed to expand as necessary. If you are submitting a paper copy of the form,
please add additional sheets as necessary.
Pembrokeshire County Council’s Local Development Plan (LDP) will be examined by
an independent Planning Inspector appointed by the Welsh Assembly Government. It
is the Inspector’s job to consider whether the Plan is ‘sound’. There is no legal
definition of 'sound' but in this context we use its ordinary meaning of 'showing good
judgement' and 'able to be trusted'.
The questions or 'tests' which the Inspector will consider in deciding whether the Plan
is sound are shown in Appendix 1 to this form. It may help you to read them and the
guidance in Part 5 of this form before you tell us what you think of the Plan and its
policies.
Before you set out your comments in detail it would be helpful to know whether you
think the Plan as a whole is sound, in line with the tests of soundness (Appendix 1),
or that all or parts of it are unsound or need to be changed.
I consider that overall the LDP is sound
I consider that overall the LDP is sound, but parts should be changed
I consider that the LDP is unsound and should be changed
□
□
□
2a If you consider that overall the plan is unsound, and does not meet one or
more of the tests of soundness (Appendix 1), please explain here which test(s)
it does not meet and why:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
2
2b In terms of your detailed response, which part(s) of the Plan are you
responding to?
(Please see question (2c) below if you want to include a new policy, paragraph or
site)
My response is about:
Policy number(s)
(and/or)
Paragraph or section
number(s)
(and/or)
The Proposals Map (including Inset Maps) (please tick  )
□
2c Would you like the Plan to include a new or amended policy, paragraph or
site?
[Tick  all that apply]
□
□
□
□
□
□
a new policy
an amended policy
a new paragraph or new text
a amended paragraph or text
a new site
an amended site area
2d If you want to add a new site, or amend an existing site, did you previously
submit the site as a Candidate site? If so, please give the Candidate Site name
and reference number (if known) – you can find these on the County Council’s
website.
Candidate Site name
Candidate Site
Reference Number
3
Part 3: Your response and suggested changes
If you do not consider the Plan to be ‘sound’ and that it should be changed, please
explain clearly why you think the changes are needed. If you think a change is
needed for the Plan to meet one or more tests of soundness, please explain.
If you are supporting the plan and wish to add details of which aspects in particular
you support and why, you may also do this here.
You may also find that you support the plan in general, but wish to see a specific part
of it changed in some way. You may also record this here.
Please be specific about any changes you would like to see. For example, if you
want new text added or text amendments, please set out the new or amended text
and explain where it should go in the Plan.
If you want to suggest a new or amended site, please indicate if you are submitting
additional material to support your response and attach a site plan identifying the
boundaries of the site you wish to be included in the Plan and provide details of its
proposed use. Any new site(s) should be accompanied by a Sustainability Appraisal
(incorporating Strategic Environmental Assessment). This information must be
consistent with the scope and level of detail of the Sustainability Appraisal conducted
by the Authority.
Furthermore any new or amended policy(s), paragraph(s), text or site(s) should refer
to the same baseline information in identifying the likely significant effect as the
Deposit Plan.
Your response should be set out in full. This will help the Authority and the Inspector
to understand the issues you raise. You will only be able to submit further
information to the Examination if the Inspector invites you to address matters that he
or she may raise.
Please note that 1. the Inspector will not have access to responses you may have
made to previous consultations and 2. it is not the role of the Inspector to make an
acceptable plan better.
Please set out your response in full below using additional sheets as necessary;
please also submit a summary of your response following your full response.
Full Response
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
4
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
Summary of Response
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
5
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
6
PART 4: What happens next?
At this stage, you can only make responses in writing (these are called 'written
representations').
However, anyone who has responded to this consultation and requested a change to
the Plan can appear before and speak to the independent Planning Inspector at a
‘hearing session’ during the public Examination.
You should bear in mind that your written comments on this form will be given the
same weight by the Inspector as any made verbally at a hearing session.
4a Do you want your response to be considered as a ‘written representations’
or (for those proposing a change to the plan) do you wish to speak at a hearing
session of the public Examination?
(Please tick  one of the following)
I do not wish to speak at a hearing session and am happy for my
written comments to be considered by the Inspector.
I wish to speak at a hearing session.
□
□
4b If you wish to speak at the public Examination, please set out below why
you consider this to be necessary?
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
Signed:
Date:
Remember to submit any supporting documentation with this form (e.g. a plan
showing any proposed new sites and a sustainability appraisal for any
proposed new sites)
7
PART 5: Guidance Notes
1. The Planning and Compulsory Purchase Act 2004 states that the purpose of the
examination of a Local Development Plan (the Plan) is to consider whether it is
‘sound’. Some respondents may wish to send in a supporting response in relation
to the plan’s policies and proposals. Others may wish to object to the Plan and in
this instance the respondent should say whether they think the plan is ‘sound’ or
‘unsound’ and what is needed to make it sound. Sound may be considered in this
context within its ordinary meaning of “showing good judgement” and “able to be
trusted”. To assess the Plan 10 tests of soundness are used. These tests are set
out in Appendix 1 to this form.
2. Where you propose a change to the deposit Plan it would be helpful to explain
which, if any, of the test(s) of soundness you consider the Plan fails. The tests
are in 3 groups – ‘procedural’ (2 tests); ‘conformity’ (4 tests); and ‘coherence and
effectiveness’ (4 tests). If you wish to object to the way in which the County
Council has prepared the Plan, it is likely that your objection will fall under one of
the procedural tests. If you wish to object to the content of the Plan, it may help to
look at the ‘consistency’ and the ‘coherence and effectiveness’ tests.
3. Failing to identify a test of soundness will not rule out consideration of your
response, providing that it relates to the Plan (or part of the Plan) and it is clear
what change(s) you are seeking. You should include all your response on the
Plan and set out your case in full and in summary on this form, using
accompanying documents where necessary. If you are seeking more than one
change and consider that the Plan fails to meet more than one test of soundness
it is not necessary to complete separate forms. However, it would help the
Council and the Planning Inspector if you would use separate forms where you
object to part of the Plan but are in support of other parts of the Plan. In other
words, all objections should go on one form and all supporting representations on
a second form.
4. Where a group shares a common view on how it wishes the Plan to be changed,
it would be helpful for that group to send a single form with their response, rather
than for a large number of individuals to send in separate forms repeating the
same point(s). In such cases the group should indicate how many people it is
representing and how the representation has been agreed by the group.
5. Please note that all comments will be made public – they will be available for
inspection at the Main Reception at County Hall, Haverfordwest, and they will also
be available online through our LDP Representations webpage
www.pembrokeshire.gov.uk/planning.
6. For information the LDP examination process will be different from the JUDP
examination in that all evidence will need to be up front. There will be no ‘Proofs
of Evidence’ given prior to the enquiry as in the JUDP; but the independent
Planning Inspector may ask questions, ask for additional information or invite you
to address matters that he or she may raise should they wish.
8
Appendix 1: Tests of soundness
Procedural Tests
P1
It has been prepared in accordance with the Delivery Agreement
including the Community Involvement Scheme.
P2
The plan and its policies have been subjected to Sustainability
Appraisal including Strategic Environmental Assessment.
Consistency Tests
C1
It is a land use plan which has regard to other relevant plans, policies
and strategies relating to the area or to adjoining areas.
C2
It has regard to national policy.
C3
It has regard to the Wales Spatial Plan.
C4
It has regard to the relevant community strategy/ies (and National Park
Management Plan).
Coherence and Effectiveness Tests
CE1
The plan sets out a coherent strategy from which its policies and
allocations logically flow and/or, where cross boundary issues are
relevant, it is compatible with the development plans prepared by
neighbouring authorities.
CE2
The strategy, policies and allocations are realistic and appropriate
having considered the relevant alternatives and/or are founded on a
robust and credible evidence base.
CE3
There are clear mechanisms for implementation and monitoring.
CE4
It is reasonably flexible to enable it to deal with changing
circumstances.
9