I have been attending a number of meetings, and receiving a number of enquiries from local authority planners, where people are still mentioning that they are working on a ‘draft submission document’, or that they have reached ‘draft submission stage’. Whilst I appreciate that the wonderful cozy old world of ‘multiple drafts’ was incredibly safe and easy, I think it is important to realize we have moved on.
When the Plan Making Manual talks about ‘Publication’ being the stage at which the authority thinks the plan is sound, and therefore ready for submission, this really does mean that the local authority should not be expecting to receive any representations which would cause it to seek to change the plan. Indeed, this is not a ‘consultation’ exercise at all. It is the opportunity for others to suggest that there are issues of soundness, and the opportunity for the authority to ensure its evidence is already in place to counter those suggestions.
The manual sets out the potential for discovery of and dealing with the extent of changes that may have to be made, but this is really as a result of unforeseen information coming back.
In order for this likelihood to be reduced as far as possible, we all need to ensure that engagement at the outset is as effective and wide-reaching as possible. We must innovate here, and move away from simple standard consultation letters. We need to find out what it is that key delivery stakeholders are interested in, and how we can ensure that their interests are at least taken into account, or shown why they cannot be. The more work done here, the less work will need to be done later, and instead of endless drafts and redrafts, the authority will indeed publish a plan with a weight of support behind it.
Publication is not the stage for further testing of the waters, rather it is the finished article, the sound plan, backed up by evidence already gathered from conversations already had, leading to a document which cannot be picked apart by any representation.
I can already hear people complaining that life isn’t that simple, and that some people always ‘keep their powder dry’ until the end, storming in with a brand new site, or a piece of evidence about a rare species or hitherto unknown habitat. It is these people in particular who must be sought at the outset, for it is these people who would have to answer the Inspector’s questions around their lack of involvement at the outset, given the way the authority reached out to them, specifically.