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Commenting on the LDP

Comments on the LDP should be made via the form the Vale of Glamorgan have made available, or online.  It's advisable to wait until the LDP has been more thoroughly investigated before commenting.

The process has been designed by the Welsh Government to prevent citizens having too much say and from influencing the decision-making process.  Opinions and problems in the LDP are not important.  Only whether the LDP meets the ten tests of 'soundness' is important.

Increasing the quality of representations
One of the hardest tasks for the council to carry out in drafting its plan will be to draw together all the representations received and to take these concerns on board through the LDP process.

Although it is important for the council to consult and engage with communities as effectively as possible the key output to improving this process will be to have an increase in the quality of representations submitted not necessarily an increase in the quantity of representations.

The key message is that central and local government want people to make comments on the land use matters that they are really concerned about in terms of the effect it will have on their quality of life and enjoyment of their environment. The aim is to reconcile and amalgamate those concerns. Different people are bound to have slightly different worries but a general consensus of the local community can be drawn together into one statement and submitted. However, local politicians still need to realise the number of people objecting...  This will be much more helpful than hundreds of pro forma type representations with no identification of the author and more crucially no identification of who coordinated the comments.

Tips for commenting on planning applications
Following the advice below will increase the likelihood of views being taken into account:

• number your concerns and set them out in separate paragraphs; 

• ensure your comments are relevant to the LDP and WG, VoGC policies/planning control

• list and classify objections in a logical manner: start with any comments on the proposed use, referring to development plans and other policy documents if possible. Then discuss design and layout issues, e.g. access arrangements, density, appearance of buildings and 

• always make sure your comments are submitted in the specified time and that your comments relate specifically to the LDP as submitted. 

Examination of Local Development Plans 
•   Each new LDP will be submitted to the National Assembly for Wales for independent examination. 
•   Examination will be carried out by an Inspector from the Planning Inspectorate. 
•   The Inspector will assess whether the plan overall is ‘sound’ (‘showing good judgement’, ‘able to be trusted’) – see below for the tests of ‘soundness’. 
•   This means the Inspector has a more important role in plan-making than in the past. 
The ten tests of LDP ‘soundness’   

P1: Has the plan been prepared in accordance with the Delivery Agreement, including the Community Involvement Scheme?
P2:  Has the  Plan  and  its  policies  have  been  subjected  to  Sustainability  Appraisal 
including Strategic Environmental Assessment?
C1:   Does the LDP have regard to other relevant plans, policies and strategies relating to the area, or adjoining areas?  
C2: Does the plan have regard to national policy in Wales? 
C3: Does the plan have regard to the Wales Spatial Plan?
C4:  Does the plan have regard to the relevant community strategy (or National Park Management Plan)? 
Coherence and Effectiveness 
CE1: Does the LDP set out a coherent strategy from which its policies and allocations logically flow and, where cross boundary issues are relevant, is not in conflict with the development plans prepared by neighbouring authorities?
CE2:  Are the  strategies,  policies  and  allocations  realistic  and  appropriate  having considered  the  relevant  alternatives  and  are  founded  on  a  robust  and  credible evidence base?
CE3: Are there are clear mechanisms for implementation and monitoring?
CE4: Is the LDP reasonably flexible to enable it to deal with changing circumstances?

When you have read the 6060 pages of the LDP Deposit, here are 46 pages on how to respond:

Click the following link to see England equivalent non statutory guidance (PDF) on how to comment:


Ian Perry,
12 Nov 2013, 07:51