Is the Development Plan Document Sound?

This checklist on what to look for in a development plan is from p7 of the RTPI briefing sheet 5 which you can download from our Virtual Library.

[Note April 2012:  This checklist remains robust, post publication of the new National Planning Policy Framework which has replaced national planning policy statements and guidance.  The main change is that there are no longer Regional Spatial Strategies to which local plans had to conform under the old system].

Is the Development Plan Document Sound

Procedural Tests – How has the document been prepared

1. The Development Plan Document has been prepared in accordance (in line) with the Local Development Scheme.

Tips: get a copy of the Local Development Scheme: Was the document in the Local Development Scheme? Does it cover the subject mentioned?

2. The Development Plan Document has been prepared in line with the Statement of Community Involvement, or with the minimum requirements set out in the regulations where there is no Statement of Community Involvement.

Tips: look at the Statement of Community Involvement and the local planning authority’s consultation statement. Was the Statement of Community Involvement followed, and are the points made in the consultation statement accurate?

3. The plan and its policies have been subjected to Sustainability Appraisal.

Tips: look at the sustainability appraisal report. How has it been prepared? What information has been used?

Conformity tests

4. It is a spatial plan which is consistent with national planning policy and in general conformity with the Regional Spatial Strategy or Spatial Development Strategy (London) for the Region. And it has properly had regard to(considered) any other relevant plans, policies and strategies relating to the area or to adjoining areas.

Tips: look at a copy of your Regional Spatial Strategy, national Planning Policy Statements, the Local Transport Plan, and any supporting studies produced by the local planning authority. Does the document being consulted on conform to the conclusions and policies made in these documents?

5. It has had regard to the authority’s Community Strategy.

Tips: look at the community strategy. Does the consultation document help to deliver the overarching objectives?

Coherence, Consistency and Effectiveness

6. The strategies/policies/allocations in the plan are coherent and consistent within and between Development Plan Documents prepared by the authority and by neighbouring authorities where cross boundary issues are relevant.

Tips: look at the other planning documents produced by the local planning authority. Will the consultation document help to deliver other policies? Are there policies and proposals that are inconsistent with wider objectives/policies? Is the document consistent with the plans of neighbouring authorities?

7. The strategies/policies/allocations represent the most appropriate in all circumstances, having considered the relevant alternatives, and they are founded on a robust and credible evidence base.

Tips: look at the sustainability appraisal, supporting studies and other locally prepared plans e.g. parish plans. What do they say about the sites proposed? Your local knowledge will be particularly useful here.

8. There are clear mechanisms for implementation and monitoring.

Tips: has the local planning authority made clear how it will monitor the policies in the plan?

9. It is reasonably flexible to enable it to deal with changing circumstances?

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At the submission stage you must relate your comments to the Tests of Soundness and you will have to say whether you think the document meets these tests and is ‘sound’, or does not meet the tests and is ‘unsound’;

>> Clearly identify the policy/proposal you are objecting to or supporting, using the reference number given in the plan;

>> Say why you are objecting/supporting (relate to the nine tests – is the document ‘sound’?) and, if you want to see a policy or proposal changed, say how and put forward your own alternative and the reasons for it;

>> Keep your comments as simple as possible and organise them in a logical order (see inset box on tests of soundness if you are getting involved at the last stage when the document is submitted to the Government to be tested by an Inspector);

>> Concentrate on the planning issues involved. These are known as material considerations (see below for more information);

>> If objecting to certain aspects of a proposal it is important to stress where you agree with the local planning authority so attention can be focused on issues of conflict. Try to show that you have understood, yet still disagree with the local planning authority’s position;

>> Identify statements, policies and proposals from other planning documents, the plan you are commenting on and the sustainability appraisal, which support your comments. These other documents could be national planning policy statements, regional policies, other local planning policies, the sustainability appraisal, or relevant technical reports and studies;

>> Refer to local issues and concerns, but try to relate them to the main planning issues. locally prepared reports/plans may help support your comments (for example sustainable community strategy and parish plans) Your local knowledge is invaluable, but try not to get sidetracked onto non-material, temporary or non-planning issues – noise and disturbance during construction and property values are typical areas to avoid.

Remember planning is here to serve the public interest. All Planning Documents are public documents and any comments you make on a planning document will be public information and will be able to be viewed by others.

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