Making Representations to the Plan-Making Process


Well we’re now into a new year and new decade and the RCA team have been reflecting on the most recent consultation season at the end of 2019. At the end of the year, the team were busy preparing representations for a wide breadth of clients to represent their sites to various Local Plan Reviews at various stages.

Some of the consultation which the team responded to have included Wyre Forest District; North Warwickshire; Bromsgrove District; South Staffordshire; South Worcestershire; and Charnwood District.

We wanted to share some expertise and knowledge with you as a result of these latest round of consultations.

  • Background Reading:

You should always allow yourself plenty of time to read the background evidence documents, this is especially important when you come to preparing those very important Regulation 19 Tests of Soundness consultations on Draft Plans. More often than not, important information about omission or opposing sites will be buried in the Sustainability Appraisal and they may well indeed have scored higher than those proposed for allocation. Allowing yourself plenty of time to read and digest background evidence will allow for a stronger submission to justify where a plan may not meet the requirements of the Tests of Soundness.

  • Challenge the Local Authority:

Don’t be afraid to challenge the Council – for example, here at RCA Regeneration, we have an in depth knowledge of the Midlands and South West regions where we have successfully applied our knowledge in our recent representations. This has included pushing back against certain proposed allocations which are unsustainable or undeliverable. Look at delivery closely – in relation to market and affordable housing – are their predictions on future delivery over-ambitious?

  • Breathe and Relax:

You should keep your representations short and to the point. Do not regurgitate information you have previously submitted under previous iterations of consultations – there is no need! The Council officers (and the Local Plan Inspector) will have enough information to read and analyse in the follow up to the close of the consultation period and Examination Hearings. The Examining Inspector may be more interested in relevant points of contention where a Plan does not meet the relevant tests of soundness.

  • At the Examination:

In the latter stages of engagement (i.e. at the Examination stages) note that your written submissions will carry the exact same weight as your verbal contributions. In this respect the Inspector will not want to hear repeat arguments verbally as they will already have taken account of your written representations within the Hearing Statements and responses to their Matters, Issues and Questions which are often set out prior to the Examination Hearings. As before, keep your responses short and sweet – the Examining Inspector will appreciate it, as there is always a lot to get through.

If you have a site that you would like to put forward during the next stage of consultation, or are currently promoting a site and wish for some planning or viability support for the next stages, then please do not hesitate to contact us on 01905 887686 or email 

We would be more than happy to assist you in promoting the site for development, whether that is residential, retail or commercial. 

Now all we have to do is await the analysis of the latest round of consultations and the start of the next consultation season over the summer of 2020.

Bring it on!

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