There is a major quandry on how to deal with the current consultation on the Croydon Local Plan, the latest draft of which was adopted by the Cabinet in July and which is being consulted on up to 17 October, and will be submitted to public inquiry next year.
Large number of comments that were submitted were ruled out by the Planners as not acceptable, not meeting the requirements, and not even commenting on whether the points raised had been looked at even if not submitted correctly or ignored.
This may be partly due to the complexity of the instructions that were given by the Council on how to submit amendments. It seemed to suggest that amendments could be proposed to the sections of the text marked in red.
In the report to the Cabinet Conservative Councillor Steve O’Connell had managed to get it accepted that there would be improved bi-partisan discussion on the next stages. Congratulations.
I drew the problem to his attention and the way so many proposed amendments have been treated will be disappointing to many people and organisations, lead to them feeling they were misled about what to do, and may reduce the participation on the next stage of the consultation.
I suggested to him that ‘It would be very helpful if you and your colleagues could explore this with the planners through the bi-partisan process, and get some clearer explanation of how further amendments can be submitted as valid in the forthcoming consultation. ..’
Cllr O’Connell raised the issue with the planners, and I received the following email comment (21 July) from Jaimee Semmens, Project Officer – Spatial Planning
‘In response to the first part of your query below, comments that were received on parts of the Croydon Local Plan: Strategic Policies that were not shown in tracked changes are not subject to consultation as they remain adopted and unchanged. Therefore comments received on these sections were not able to be accepted by the Council. This was stated at the beginning of the Strategic Policies – Partial Review (Preferred and Alternative Options) document in the “Using and commenting on this document for consultation” section.
Similarly, during the publication phase, representations can only be made on the track changed sections of the Strategic Policies document. To improve the public’s awareness of the requirements and sections in the Strategic Policies document that are subject to consultation, Council officers will ensure that the above text is clearly stated on in the strategic Policies document, on the Council website and on representation forms. Council will also have a “Frequently Asked Questions” webpage including and answers to the following questions; “what can be included in a representation” and “what cannot be included in a representation”.
During the publication phase, representations can be made between 5 September and 23.59 on 17 October 2016 by:
- Emailing firstname.lastname@example.org or
- Completing the representation form (which will be made available at libraries and on Council’s website) and emailing it to email@example.com or posting it to Spatial Planning Service, 6th Floor Zone B, Bernard Weatherill House, 8 Mint Walk, Croydon, CR0 1EA.
Any representation will need to contain a name and address and must worded to demonstrate whether the person/organisation thinks that the plan has been positively prepared, justified, effective or consistent with national policy, and the reasons why, using the below criteria:
- Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
- Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence.
- Effective – the plan should be deliverable over its period based on effective joint working on cross-boundary strategic priorities.
- Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework
It is not the most beneficial way to make a representation to simply state whether you object or support a part of the plan. Every effort should be made to link a representation to at least one of the four requirements set out above.
Should you have any queries regarding the above, please contact the Spatial Planning Service on 020 8726 6000 or 020 8407 1385, or by email at firstname.lastname@example.org.’
A more detailed explanation and access to the documents is at https://www.croydon.gov.uk/planningandregeneration/framework/localplan/clpreview
So many individuals may want to see whether they can re-submit their rejected amendments in the form outlined above. Later on they may wish to write to the Public Inquiry Inspector to complain about the treatment of their proposals.