ADD UPDATE, 19 July 2018: Since we posted our guidance on submitting representations on the Local Plan last week, two things have happened. Firstly, several people have told us the whole process remains too complicated. And secondly, Eastleigh Borough Council (EBC) have listened to our criticisms about their online form and made several important improvements. As a result, while our template [link] remains a valid way of submitting a representation, EBC’s form may now be the easier option.
While EBC’s online form may still look mind bogglingly complicated, it is actually a lot simpler and quicker than it looks. A few vital tips:
- You do not have to answer all or even many of the questions. The main thing is that you are seen to make clear you think the Plan is unsound. It is ADD’s job to provide a detailed critique – and we are employing consultants to help us do so.
- You only need complete the first two sections – i) About you (your details) and ii) Overall assessment of the Local Plan – though we encourage those who so wish to complete other sections.
- Answering section two (Overall assessment of the Local Plan): When providing an overall assessment, we suggest you answer the legal compliance question by saying you are unsure. ADD is currently taking advice on this question. Our main argument is about its soundness. If you wish to object then you have to answer ‘no’ to the question: “Do you consider the Local Plan to be sound?
- You will then be asked to make comments about the soundness. It is essential to begin your answer “I/we believe the Local Plan to be unsound because …”. If you fail to use these words your submission is likely to be ignored.
- All the other sections are optional. If you complete any of them, please always start: “I/we believe this policy to be unsound because …” This should ensure your views are considered.
- Finally, make sure that your objection has been sent – job done!
Some of points you might like to make in answering section two:
Answering section two. Your comments can be brief. Below are some of our main objections. There’s no need to list them all, and feel free to add your own.
a) We believe the plan was predetermined. Emails that the council was forced to make public suggest that the leadership was already deciding the Local Plan in detail months before the public consultation.
b) The council then ignored the results of its own public (Issues and Options) consultation in December 2015, which showed that options B and C were by far the least popular. In fact, option B (including the new road) had more objections than the other nine options combined.
c) The council has made no serious attempt to consider the suitability of other options. In their comparison of options B/ C and D/E it uses the phrase “it is considered that” no less than 61 times. This is no substitute for hard fact.
d) It voted to proceed with the plan on 11 December 2017 when nearly 40% of the evidence was still missing including the vital environmental impact and traffic reports.
e) It failed to provide prior consultation to bodies it was required to advise such as Hampshire County Council and the Environment Agency, making the consultation process less well informed.
f) Much of the council’s evidence is incomplete and vague (e.g. traffic impact assessment) and poorly costed (e.g. the proposed new link road).
g) The council appears to have ignored or even contradicted its own evidence in places (e.g. impact on the River Itchen Special Area of Conservation).
Other sections. You may be asked whether your comments apply to the bold text or to the rest of the text or both. Unless you have a lot of time, we suggest you stick to the bold text. As already stated, your main aim should be to register an objection to the soundness of the Plan. ADD will provide the detail.
Many people will want to answer section five – about Fair Oak and Bishopstoke, which would lose their identities, suffer horrendous levels of traffic congestion and see local amenities such as ancient woodland permanently and seriously degraded, according to the Woodland Trust among others.
Arguments should relate to good planning – for example, damage to ancient woodland and the River Itchen, damage to the landscape, the fact that the council has not modelled the traffic impact on the national park or adequately considered the Allbrook rail bridge and how the siting of the development would add unnecessarily to car use. Simply stating that you do not like something will not wash.
Again, having said you ‘oppose’ a policy, start your comments with “I/we believe the policy to be unsound because…”
For ideas for completing sections two and five of EBC’s online form, please click here – though DO REMEMBER TO USE YOUR OWN WORDS. If you use any of these examples verbatim, it will not count as a separate representation.
Please also be aware that EBC will likely want to use its form to demonstrate there is broad support for many of its policies – hence why it asks respondents to state whether they support/oppose its policies. This is not relevant to the planning inspector. What’s relevant is whether the Plan is sound or not.
Good luck! Any questions, please contact us via [email protected].
