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How To Comment on a Planning Application  

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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 your argument.

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 view.

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 anyway.

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 view

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.

Last modified 18/03/11

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