This page originates in a desire by the Planning
Department to provide guidance on how to oppose a planning application
which it disagreed with. However, it also wished to avoid writing
the the guidance itself - or, at least, avoid having to cover
the guidance under its own budget - so it found a semi-defunct
section of the Order website, revived it and presented the team
involved with an article outline as they emerged from hibernation.
The guidance on commenting on planning applications
below is the result of this intervention. No guarantees are given
as to how useful it is; we certainly can't guarantee that if
you use it your argument will be successful. After all, someone
arguing the opposite viewpoint might use it too.
1) Know what you are commenting on
This always helps. You should provide the
reference number for the plans at the beginning of your letter
and ensure that anyone reading said letter will understand how
your comments fit in with the scheme being proposed. Don't comment
on a proposal to build a house by describing the risks of nuclear
reactors unless the people planning to build the house intend
to incorporate a nuclear reactor.
You should also ensure that whatever plans
you are commenting on are the plans that the council will be
judging. Schemes will often go through several versions, eradicating
some problems and creating new ones. If you highlight an eradicated
problem it's a waste of quality typing which could have been
devoted to complaining about a valid one and it also undermines
This point can be met by simply looking over
the plans. You'll soon find something to comment on.
2) Know what your position is
You are not writing an English essay. The
council officials who will be reading your letter do not want
to read endless points of "We should consider this... but
on the other hand... however... it should also be considered".
Simply lay out whether you are in favour of the scheme or opposed
to it, give some sort of reason as to why and try to avoid ending
up in the "Don't know" pile by not having an evident
Not having a proper position thought out for
your final letter will seriously wreck your ability to actually
make a point. Few people can get across their opinion on a point
if they don't actually have one - unless it's a stock opinion
drawn out of a hat, in which case what are you doing commenting
on a scheme that you don't care about?
If you start from a decision to oppose or
support and then attempt to justify that opinion that's fine,
as long as you can produce a few decent arguments for your opinion.
Making a decision and then justifying it is how your brain works
3) Know when you're becoming a bore
While the council officials are paid to read
your opinions, they may still go to sleep halfway through a ten-page
letter on the impact of analytic and algebraic topology of locally
euclidean metrisation of infinitely differentiable Riemannian
manifold on a small housing development. Get your point across
in two pages at the most. It will also save on postage costs.
4) Don't be too jovial
Planning applications are a serious matter
and a letter filled with jokes, asides, references to Tom Lehrer
songs about Russian mathematicians (see point 3), etc etc. is
unlikely to go down particularly well.
5) Stay roughly within the law
Letters to councils on planning applications
are not covered by the absolute privilege defence to libel law.
Anything you say will be taken down and may be used in evidence
against you if it's sufficiently rude about one of the parties
involved or engaged in threatening violence if you lose. If you
don't give a name and address then it will be rather less
easy to find out that you wrote the letter but don't expect the
council to read it.
(If you are willing to stake your house on
being able to prove your comments about the applicant/lead opposer
being the illegitimate child of the former Foreign Secretary
and you think that it is relevant to the planning application
- which it probably isn't - then do feel free to put it in.)
6) Give the council reasons to follow your
Councils like to have reasons for approving
or rejecting planning applications. Since making up their own
reasons doesn't go down well with the losing side, being able
to point out that lots of people raised such-and-such an area
as an issue is useful.
7) Appear normal
Weird people are a nuisance to councils at
the best of times. While your opinion that 9/11 would not have
happened were it not for those European robot cats who write
all our law these days may be a valid view in your online social
circle, it is not necessarily widely held and may, if presented
incorrectly to the wrong kind of council official, undermine
good points in your article. Even if it may be relevant, try
to avoid bringing up distinctly non-mainstream stuff.
8) Provide something different
This can occasionally have to take precedence
over point 7, although it shouldn't take precedence over point
5. If you know something a bit geeky about the circumstances
surrounding the planning application then the odds are that the
council doesn't. Put it in - with suitable care - and it will
comply nicely with point 6.
9) Be aware of the area
Firstly, not complying with this runs the
risk that you can come across as someone who comments on random
planning applications because you have nothing better to do with
your time. See point 7.
Secondly, you can risk pulling up issues or
claiming benefits which don't actually apply in the relevant
case, even if they do apply in your local area.
Thirdly, the council officials are likely
to know the area and if you start using incorrect place names,
missing notable bits of geography or misdescribing junctions
you'll soon confuse them, which won't help your argument.
10) Non-locals should not provide local
addresses to appear local
If you are aware of the area then you can
still raise perfectly good valid points. Lying won't make them
any more valid but may provide a nice distraction for anyone
seeking to squash your view. Apart from that, you run the risk
that the council official who reads your comment lives at the
address that you give in your letter.
11) Don't go over the top
Unless dealing with plans to build a US base
intended to attract Russian nuclear missiles to detonate over
your village rather than in New York, you are probably not dealing
with a scheme which is so madly important that it justifies wittering
for hours about life or death situations. Stay down to earth.
See point 7.
12) Don't be put off by the other side
If an argument is so good that there are no
holes in it then the argument is wrong. Any debate worth having
has multiple points of view and it will always be possible to
support or oppose any given application.
Supporters: Much of the argument on your part
is done by the actual application, but additional comments are
always handy and the council is interested to see if people think
that the application is a good idea. If there is massive overwhelming
opposition but you happen to think that the plan is a good idea
for various overlooked reasons, sit down and write to the council
setting your points out.
Opposers: There will almost always be more
supporters. Their job is, after all, easier. However, the council
will be looking out for a good argument to reject the scheme
on and since the applicant is hardly going to explain why their
application should be rejected you'll have to do so.
13) Don't say nasty things about the council
Telling the council that any reasonable council
would decide X or that they're all barking Eurosceptics and will
inevitably conclude Y won't endear you to them and probably will
undermine your argument.