- STEP 1: Map / List your objection points.
- They need to directly relate to documents, policy numbers, paragraph numbers, evidence statements that are found in the Examination Library.
- Again, the Inspector may stop you if these points have been raised by someone else.
A link to some but not all objection points
- STEP 2:
- Assemble evidence and critique
- Review your evidence, including your documents, statistics, imagery, surveys, contemporary notes, previous correspondence.
- Site-specific examples can be compelling.
- The strongest points in examination will be those with evidence.
- If you have questioned the council’s evidence previously, check if they have come up with any evidence that you need to respond to.
- Include reasoned argument by a local person/community representative about what has/ has not worked in the past, and site-specific examples of how the proposed policy will impact the area.
- This will be more engaging and may bring unseen perspectives to the attention of the examiner.
- Don’t forget to include evidence that you want to rely on at hearing stage – new evidence can’t be introduced at that stage.
- Don’t underplay local insights and experience.
- STEP 3: Collaborate and consider your tactics
- Identify who has made similar points to you. Can you help each other with evidence?
- Can you align your points while providing different evidence?
- Do you agree on the tactics (e.g. do you both think the policy needs a complete rewrite or just an improvement?)
- Don’t leave it too late to collaborate with people who share common views on the issues and the solutions/tactics.
- STEP 4: Write down your points / statements
- If you are fundamentally opposed, then you would (if you have evidence) argue that the policy is unsound and suggest new wording for the numbered policy or the ‘reasons’ – or both.
- By reference to the document / policy / statements etc, state which part(s) is/are unsound. Which of the soundness criteria does it fail on? Why?
- Remember, other may be in favour of the policy and will make clear they don’t consider it unsound.
- Keep in mind that the strategic policies (SP) [and “strategic vision”] will have the soundness tests applied in a ‘proportionate’ way whereas the development management policies / site allocation policies / implementation policies will have the soundness tests applied more stringently.
- Don’t ‘expand’ into new points that do not relate to your original representations. You can broaden the evidence and the reasons for your points but you cannot bring in completely new points.
- It is suggested that a maximum 3,000 word count on policies you consider unsound. It is best not to write solely about the Strategic Policy or the Area Vision without relating your concerns to the development management policies or site allocations or implementation policies.
- Don’t include links to webpages in your statements, refer to the document by the EIP number. Don’t include personal identifiable information (e.g. the health status of someone) without consent.
- STEP 5: give it a read through and submit it by the deadline
- Do to leave this to the last minute as a read through (the next day) will help you write a concise, engaging, and persuasive statement. Ask a friend or a collaborator to review it.
- Review your tactics. You might decide that your original tactic (e.g. to say the policy wasn’t sound) isn’t strong enough. You can deal with this expressing conditional support.
- It is generally best not to ask someone else to write it all for you, as the process of writing will help you marshal your arguments for the hearing (if you choose to appear at the hearing). There is no need to be very formal or excessively courteous, or in a way that you wouldn’t normally write in, say, a consumer or business situation.
- Don’t forget to include any evidence you want to rely on in the hearing.
That said: Next is a list of the points / statements why parts of the Local Plan are unsound.