Changing proposed site allocations at publication stage - Public forum - Planning Advisory Service (PAS)

Hi Dave. I post this answer more as something for people to think about and challenge than as a definitive 'right answer' (there won't be a single one of those anyway). I think the key issue is to think about providing the right opportunity for comment and challenge on the 'new' options. Put simply, if you put something in front of an Inspector that no-one has had appropriate opportunity to debate and comment, you will probably be asked to go back and do provide that opportunity. It's not as daunting as suggesting a 'whole thing again' approach though. I think you can clearly justify that what needs to be consulted/opened up to engagement on is just the new sites. You can perhaps think about a quick summary of where you had got to, and that the existing sites, on which people have had chance to comment, are not re-opened for debate. You would in essence propose this as a 'focused change' to the document. As long as you are not altering the overall direction of the DPD. There may be a 'trick' to save consultation fatigue, whereby you can run the new content alongside the publication consultation, rather than having it come first, followed by publication consultation. However, that would imply you know the final content of the plan already, which may lead some to conclude the consultation on the new sites was not a real opportunity to test opinion. So, in summary: 1) Clarify what's now up for consultation/debate, and set out clearly what isn't and why ('evidence', presumably being the key overarching reason) 2) Allow appropriate time for engagement and responses 3) Show how you've responded to the issues raised 4) Proceed to Publication (or Submission if you can run the new sites consultation in parallel with the publication). In any event, if you do have to run 2 consultation exercises, one after the other, it still won't be as lengthy/detailed/costly, as you can limit the comments to the focused changes (new material). As with all my comments on 'procedure' I would ask you to seek your own legal counsel advice. I hope this helps, in that it may provide food for thought. Adam

There doesn't seem to be much point in consulting on what cannot be changed! We undertook further consultation and SA on alternative sites and issues arising out of the emerging options consultation. This will enable changes to be made to the portfolio of sites put forward.

Thanks very much for your responses. I can see that if we were looking to introduce 'new' site options as land allocations we need to consult before publication stage. We may be looking at putting forward land allocations in the publication draft that were the subject of consultation as 'other site options' at the regulation 25 public participation stage. We will probably still undertake a focussed consultation on these sites if they are now the Council's preferred site options for allocation and we would do this prior to publication - but welcome any views on the procedural necessity of this. Dave Sykes Harrogate Borough Council