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Places for Everyone Consultation  Aug / Sept 2021 - some notes on how to respond

The response requirements for this particular consultation are specific and to that end we have prepared some notes to help you formulate the correct method of response.

These are technical planning concepts that need explanation for the lay person.


Soundness is a technical planning term that in lay terms means:

  • Positively prepared:

    • Is the strategy appropriate for Greater Manchester and your locality?

  • Justified:

    • Have all alternatives been taken into account?

    • Are the proposals supported by evidence?

  • Effective:

    • Can the proposal be achieved?

    • Can the proposals be achieved in the timescale required?

  • Consistent with national policy:

    • Will the proposals avoid damage to the environment and climate, and allow the quality of life for future generations to be maintained? Do the proposals mitigate and adapt to climate change?


Legal compliance involves further technical planning terms, but the lay person can consider whether the council has:

  • Carried out consultations in line with the statement for each of the nine Local Authorities, which details how they will engage local communities and other interested parties in producing the plan [Statement of Community Involvement].

  • Worked with neighbouring authorities on strategic issues that cross boundaries [Duty to Cooperate]

  • Included policies which tackle climate change and its impacts

  • Assessed the extent to which the emerging plan, when judged against reasonable alternatives, will help to achieve relevant environmental, economic and social objectives [Sustainability Appraisal and Habitat Regulations Assessment].

  • Prepared the plan in accordance with the latest Local Development Scheme (LDS) for the nine Local Authorities participating in PfE, which informs the public about the current planning policies for the local authority.

For those who wish to go into more depth, these aspects are expanded here


GMCA will collect all your responses and pass them on the Inspectors prior to the Examination.

Please do not include any personal information, in the text of your response, but write in general terms.

Please note the following:

  • Only responses which address whether the plan is sound will carry any weight with the Planning Inspectors at the Examination.

  • You will need to supply your name and address in order that the Inspectors to be able to consider your response. GMCA will only publish your name, not your address or contact details.

  • You will need to state the modification that you are requesting in order that you may qualify for a chance to speak at the Examination. This could be as simple as “please delete this policy”.


You can respond via the online portal, via email or via the post. Important information on how to submit a response can be found on the GMCA website: How to make a response, which provides the following to assist you:

  • Template document to download, which you are advised to use for responses via email or post

  • Consultation guidance notes

  • How to construct an effective response

  • List of documents supporting the main plan document

  • Frequently asked questions

  • Glossary of terms

  • How to use GM mapping

  • Representation procedure


Please do not include any personal information, in the text of your response, but write in general terms.

The link to submit a response online is here. You can make a start on the survey and then save it in order that you can return later to add more.


If you wish to attach a document to support your response, you will find the option to do that in question 16 of the survey. You can upload up to 5 documents with your response, each one can be up to 25 MB. There is also the option to insert a link to a website as supporting evidence in question 17.


We recommend using the online route if possible, or submission via email. Responses submitted via post have to be typed up by GMCA to produce an electronic version.


You can find information from GMCA about the PfE plan, what it covers, how it differs from GMSF, and what this consultation means here.


More information on this can be found on the GMCA website here.


For those of you who wish to know more technical details about this stage please read on. You can also download

all of this article by clicking on the pdf image.

Regulation 19 Consultation and Examination

This stage of the process aims to test the soundness and legal compliance of the plan.



The tests of soundness are set out in National Planning Policy Framework paragraph 35 as follows:

  • Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;

  • Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;

  • Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and

  • Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies the National Planning Policy Framework.

  • In addition, to be found sound the plan must adopt proactive strategies to mitigate and adapt to climate change in line with the provisions and objectives of the Climate Change Act 2008, and co-operate to deliver strategic priorities which include climate change.

Legal Compliance 

  • The plan should have been prepared in accordance with with the latest Local Development Scheme for the nine Local Authorities participating in PfE.

  • The plan should be accompanied by a Sustainability Appraisal and Habitat Regulations Assessment.

  • Consultation on the plan should have been carried out in accordance with the Statement of Community Involvement for the nine Local Authorities participating in PfE.

  • GMCA should have worked collaboratively with neighbouring authorities and prescribed bodies on strategic and cross boundary matters, known as the Duty to Cooperate.

  • The plan should comply with all relevant laws including the Planning and Compulsory Purchase Act 2004 and the Town and Country Planning (Local Planning) (England) Regulations 2012.

  • In addition, there is a statutory duty on local planning authorities to include policies in their Local Plan designed to tackle climate change and its impacts. 


If you think that any of the requirements outlined above have not been fulfilled in PfE, then now is your opportunity to have your say in the consultation.


Submission to the Secretary of State

GMCA will collect all your responses and prepare a summary of the key issues raised. The plan, supporting evidence, regulatory documents, all your responses in electronic form and GMCA’s summary of key issues raised will be submitted to the Secretary of State. A panel of Inspectors will be appointed to conduct a public Examination of the plan.

The Examination

The Examination differs from an Inquiry or a Planning Appeal. The Examination is an inquisitorial rather than an adversarial process. Before the hearing sessions the Inspectors undertake an initial assessment of the plan, the evidence base and the representations. The Inspectors decide which of the issues that were raised in the Plan consultation they wish to explore and who they want to invite to the hearings. The hearings are round table discussions chaired by one or more Inspectors who invite representors to have their say. A programme officer is appointed to handle all the administrative tasks associated with setting up the hearings and establishing contact with the representors.


Once the plan has been submitted for examination, no additional written material should be submitted, by the LPA or any other party, unless it has been requested by the Inspector.


The plan is assumed to be legally compliant and sound because it has been presented by the council to the Secretary of State as a sound plan backed up by evidence. The Inspector’s task is to determine whether any of the representations submitted to the consultation demonstrate that it not legally compliant or sound, by probing the supporting evidence submitted with the claim. Failure of the Duty to Cooperate cannot be fixed and in that event the plan is rejected. Modifications can be made to correct aspects of the plan that the Inspectors find unsound.


Major modifications (Main Modifications) to the plan are subject to public consultation.


Inspector’s Report

After the Examination the Inspector prepares a report, summarising the outcome of the examination and, where appropriate, the principal changes to the plan made by the Main Modifications and why these are necessary. It is sent to the LPA for fact checking before the final report is issued.


The legislation enables the Inspector to recommend a Minor Modification only if the plan would otherwise be unsound or legally non-compliant. The Inspector has no power to recommend other changes, even if they would improve the plan. Representations are sometimes made about points that do not bear on soundness or legal compliance. The Inspector will not make recommendations on those points.


Once the Inspector’s final report is published the LPA must take the appropriate steps to adopt the plan.


Further information can be found in the Government’s Procedure Guide for Local Plan Examinations

The SGMGB Management Committee

27th August 2021