HOW TO COMMENT ON A PLANNING APPLICATION ...
Comments must be on planning grounds - the laws and guidelines that guide all planning applications. They include the National Planning Policy Framework (which sets out the government’s planning policies for England and how they are expected to be applied), the London Plan (the spatial development plan for London) and Hounslow's local plan (which describes Hounslow's policies). For many local planning applications, you won't need to look in detail at these plans; they are most useful when commenting on bigger developments such as The Chiswick Curve/Holly House. Instead, the list below should be a reasonable guide on what to consider when commenting on a smaller development.
All planning decisions are based on evidence and must be defensible and reasonable.
Like many councils, Hounslow works with developers to develop acceptable plans, charging a fee for this service, and guides residents to develop acceptable plans, also charging a fee for this service (check this list and look for householder developments). Unlike many councils, Hounslow does not help residents comment on others’ plans so here’s our guide to commenting on a planning application – big or small.
Make the most of your comments
- Individual letters from many people are much more effective than a petition.
- Template letters/cards will be counted together as one submission and are less effective.
- Using your own words gets attention.
- Don’t worry about style, neatness or how you write; being yourself impresses.
- Don’t be offensive or discriminatory; they are not planning arguments.
- You don’t have to raise every aspect below; what bothers you or supports your arguments?
What you need to consider and do
- Planning decisions must be based on evidence, not opinions or hunches; they must be defensible; they must be reasonable. Provide information that supports these fundamental principles.
- Describe the area that will be affected (its character such as whether it is a quiet residential area, is generally low-rise, has an open aspect, is tree-filled, is already impacted by other factors - paint a picture of your immediate surroundings).
- Say if and how it will affect or impact on you, your road, your neighbourhood.
- Say if others, such as residents’ associations or community groups, support your position.
- Focus on size and visual impact; is it in scale with nearby properties, the area?
- Is it land-grabbing (taking land that has another specific purpose)?
- Is it garden-grabbing (using garden space to build an extra property)?
- What about density or over-development?
- Is it overbearing, out of scale, out of character? If it is ugly, say so.
- Does it overlook or overshadow, will it intrude or cause loss of privacy or light?
- Will it affect services: schools, access to GPs, transport, traffic, parking, roads?
- Will it create noise or disturbance after (not during) construction?
- Will it affect or be affected by air or noise, safety?
- Will it damage trees or require trees to be removed; is landscaping an issue?
- Is it in or will it affect a conservation area or impact on a nearby listed building?
- Does it meet the Hounslow Local Plan (here) and/or the London plan (here) and does it follow Hounslow planning guidance (here)?
- Put the reference number(s) and location in the heading/email subject line.
- Always meet the deadline!
OFFICER RECOMMENDATIONS, THE PENDING LIST AND CALL-INS
Every week, on a Friday afternoon, Hounslow's planning team publishes a pending list - a list of applications pending a decision recommended by a planning officer. If you disagree with a recommendation, you can ask for a call-in of the application, so that it is considered by the planning committee. You must act fast: call-ins can only be made within a week of the pending list being published and must be done through one of the councillors of the ward containing the application you are concerned about. Not all call-in requests are successful; a call-in will only be accepted on planning grounds.
If the call-in is accepted, you will be told the date of the planning committee where the call-in will be heard. Your role is then to try to persuade members of the planning committee to change the recommended decision of the officer based on all or some of the following points:
- demonstrate in reality the reasons why the application should not be approved (for example, as has happened in recent cases, putting up a simple barrier to demonstrate height and impact on loss of light or erecting a pole to show the height of a building and where its impact will be most damaging)
- invite members of the planning committee to visit the application site to see its impacts in reality
- provide a briefing for members of the planning committee (don't send this as an attachment, put it into the email and make it immediately impactful); councillors have a lot to read, make it as easy for them otherwise your email could be glossed over quickly; consider writing a letter instead of an email
- prepare your five minute (total for all objectors, not five minutes each) presentation to the planning committee including deciding who is to speak on which aspect (play to objectors' strengths)
- provide photos, drawings, graphs, illustrations to the committee officer to illustrate points in your presentation
- if there is too much to cover, use your presentation to suggest questions you would like to be asked
- be prepared for disappointment and to find the process challenging; discussions follow a strict order which often leaves objectors feeling short-changed plus committee members must make their decisions based on the guidance above and many will not know the location and its specific sensitivities
- rehearse, rehearse, rehearse including perfecting timing (you will be cut off after your five minutes)
The councillor calling-in the application will help you through the process and will support you at the committee though your case is usually made most effectively by you and your neighbours because of its direct impact on you and your neighbours. We can't over-emphasise the importance of preparing, as recommended above, and rehearsing.