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PLANNING APPEALS

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PUBLIC INQUIRY

Public Inquiries are conducted in accordance with the Town & Country Planning (Inquiries Procedure)(England) Rules 2000 and the Town & Country Planning Appeals (Determination by Inspectors) (Inquiries Procedure)(England) Rules 2000.

The difference between these two sets of rules is simply that the former are those which are applied to the Secretary of State in considering Planning Appeals, whereas those in the latter govern circumstances where the Appeal is to be heard by an Inspector appointed by the Secretary of State.

The rules are laid down to provide a framework within which Planning Inquiries may proceed efficiently and effectively and without prejudicing the impartiality of proceedings.

Failure by any party to comply with the rules could result in an award of costs, if it can be shown that the failure incurred the other party in unnecessary expenditure due to unreasonable behaviour. (See costs for further information).

  Public Inquiries are conducted in a formal framework and you are strongly advised to seek legal advice before proceeding, particularly if you intend conducting your own case.

 Either party may request the Appeal to be conducted by way of a Public Inquiry with evidence being given in a formal manner before an Inspector. In larger cases and some specific circumstances, the Secretary of State may make the final decision following advice received from an Inspector appointed to hear the evidence at an Inquiry.

 INITIAL PROCEDURE

The initial part of the procedure follows the standard format; with grounds of appeal being submitted, acknowledgement by the Inspectorate, the Planning Authority producing their questionnaire, together with confirmation of whether they wish to hear the Appeal by way of a Public Inquiry.

On receipt of the Appeal form and relevant documentation, the Inspectorate will send out notification of the start date and the timetable for conducting the Inquiry. Notwithstanding any request for a Public Inquiry, the Inspectorate will give consideration to whether the Appeal is more suitably dealt with by way of a Hearing, notwithstanding the request by the other party.

The Case Officer for the Inspectorate will contact both parties to establish an appropriate date or dates for the Public Inquiry and each party will have an opportunity to refuse one date before arrangements are settled.

Both parties are required to produce a Statement of Case.

The Statement of Case contains a full outline of the case to be put at the Inquiry, together with a list of relevant documents, plans etc. This Statement ensures that the parties know all about each other’s case at an early stage, both in terms of ensuring that evidence is not "hidden" and to encourage a better understanding of the issues. This might encourage negotiation before the Inquiry over misunderstandings or alternatives that may resolve the problem. If remedial arrangements are possible, then this early exchange of statements helps to avoid late cancellations or requests or postponement of Inquiries nearer the established date.

The Local Authority are required to send two copies of their Statement of Case to the Inspectorate and a copy to any statutory party within 6 weeks of the relevant date (ie the start date notified initially to all parties); Or 4 weeks after any pre-inquiry meeting.

The Appellant must send two copies of their Statement of Case to the Inspectorate and a copy to any statutory party within 6 weeks of the relevant date (ie the start date notified initially to all parties); Or 4 weeks after any pre-inquiry meeting.

The Inspectorate will then forward copies of the Statements to the respective parties.

Further information or receipt of particular documents referred to in the Statements can be requested through the Inspectorate, and the Inspector can also request further information from either party. In all cases two copies must be sent to the Inspectorate within the time specified.

 Strict adherence to timescales is required. Late submissions will normally be disregarded.

Previously the rules allowed a later transmission for the Appellant, however, the new rules now require simultaneous exchange in order to avoid "cross-examination by post". The new rules now place the Inspectorate in the role of 'Post Office', forwarding the various documents between the parties to speed up the process.

If you are a third party who has made representations initially at the planning application stage, you should re-submit these, together with any additional comments, at the Appeal stage. Although your original representations will be considered in the general paperwork, any further written comments at the Appeal stage will be taken into account. You also have an opportunity to appear at the Public Inquiry to make any representations verbally to the Inspector.

The Secretary of State may require you to supply a Statement of Case in advance of the Inquiry, which should be sent within four weeks of the request.

 

Copies of third party representations will be circulated to the principal parties. It is often better to incorporate any comments on third party representations within your general Proof of Evidence rather than singly in an ad hoc manner.

The appellant or the planning authority may comment in writing upon any Statement of Case within 9 weeks of the starting date. Two copies of any comments shall be sent to the Inspectorate for forwarding accordingly.

Third parties who have submitted a Statement on their own behalf may comment upon any of the other Statements not less than 4 weeks before the date of the Inquiry.

Site notices are sent out for display on the appeal site and any interested parties are notified by the Local Planning Authority giving information about the date, time and location of the Inquiry and requesting any comments to be sent to the Inspectorate within 28 days.

PRE-INQUIRY MEETINGS

Although unusual, it is possible for the Inspector to hold a pre-inquiry meeting into any Appeal in order to outline the administrative procedures for the Inquiry and to ensure that all parties provide appropriate information in order that the Inquiry may proceed speedily and efficiently.

An Inspector is required to give at least two weeks notice of any pre-inquiry meeting.

FIXING THE APPEAL DATE

The date for a Public Inquiry should normally be within 22 weeks of the starting date or within 8 weeks after a pre-inquiry meeting unless extended by the Inspectorate for particular reasons.

PROOFS OF EVIDENCE

The timetable for the Inquiry will indicate the period by which Proofs of Evidence must be exchanged. This must be at least 4 weeks prior to the date of the Inquiry.

Proofs of Evidence that are likely to be in excess of 1500 words should be summarised.

Two copies (appellant or local Authority) or three copies (third parties) should be sent to the Inspectorate with a copy to any statutory party and the Inspectorate will then forward copies of respective proofs to the parties.

At least 4 weeks prior to the Inquiry the local authority and the appellant must send in a 'Statement of Common Ground'. This statement is prepared jointly and contains factual information about the proposal.

PROCEDURE AT THE INQUIRY

On the appointed day for the Inquiry, all parties will be required to attend at the notified Inquiry venue in order that the Inquiry may proceed to start promptly at 10 am.

Public Inquiries do not usually start on a Monday or before 10 am on the first day, although alternative arrangements for Inquiries that run over into subsequent days can be made, in order to make the best use of time.

The Inspector will open the Inquiry by introducing himself and any assistants he may have with him, outline the various procedural requirements and indicate how he intends the Inquiry to proceed.

He will advise the Inquiry that he has received and considered the Proofs and other documents, and may have made an informal site inspection in advance of the Inquiry. The Inspector may then enquire of both parties how long they consider their case presentation is likely to take, in order that Inquiry timings can be assessed. Any third parties will also be invited to provide their details and whether or not they wish to speak.

The Inspector will endeavour to accommodate requests for early appearances by third parties due to personal timing or other limitations, but it is normal for third parties to be heard towards the end of the Inquiry.

After the preliminaries have been conducted, the Council will be invited to present their case. Under the new rules the Council's case is outlined first, but the appellant does have the final word.

PRESENTING YOUR CASE - [See also APPEAL PRESENTATIONS]

This may involve reading certain passages from the submitted statements and other documents, but should not necessitate rehearsing the whole of the written evidence.

Although Proofs of Evidence and summary statements will be taken as read, it is generally important to highlight the key issues which gave rise to the grounds of Appeal and upon which the Appellant is relying in seeking to overturn the Council’s decision.

The Inspector will use his discretion to enable or require more than summary information to be read out, particularly where complex evidence has been submitted and it is necessary to ensure that all parties have a clear understanding of the salient points.

The Appellant may call any evidence in support of their Appeal. This may be testimony from Expert Witnesses or other parties, which have a direct bearing upon the matter at hand.

Witnesses will be subject to cross-examination by the Local Planning Authority and the Inspector may also ask his own questions of the witness before they complete their evidence and the next witness is called.

The same procedure is adopted by the Local Planning Authority who tender their own evidence and witnesses in support of their case. Here again, the Inspector will be entitled to ask his own questions of the Local Authority witnesses.

Third parties, who have expressed an interest in addressing the Inquiry, will then be invited to make their statements and will be open to cross-examination accordingly. It is sometimes the case that third parties will be allowed to ask questions of the main party's witnesses.

The Local Planning Authority will then be invited to sum up their case, after which the Appellant will be invited to do the same - effectively being given the last word.

CLOSING THE INQUIRY

At this stage the Inspector will usually consider any requests for an application for costs by either party. This will normally be done in the form of a statement explaining why it is considered that the other party concerned has acted in a manner which has incurred the applicant for costs to incur additional expenditure, by virtue of unreasonable behaviour. Similarly, the other party will be invited to defend their position and/or make any counter-claim for costs.

The Inspector will then make any necessary arrangements for carrying out a formal site inspection. This may not always take place on the same day as the Inquiry closes and may, in any event, have already taken place during the course of the Inquiry where it has been seen expedient to do so.

Assuming there are no other matters to be discussed, the Inspector will then formally close the Public Inquiry and adjourn to the site inspection.

SITE VISITS

This inspection is only required in order for either the Local Authority or the Appellant to be able to point out important site features and verify details that have been referred to in the submissions. Third parties may also indicate relevant matters that have been raised in their evidence.

NO DISCUSSION OF THE MERITS OF AN APPEAL IS ALLOWED AT A SITE VISIT.

In certain circumstances it may be unnecessary for the Planning Inspector to be accompanied by either party, if the site can be seen from a public highway or other publicly accessible land. Unaccompanied site visits will not require formal arrangements to be made with the Council or the Appellant.

In the interests of maintaining impartiality, the Inspector will not permit a site visit to take place accompanied by only one party to the Appeal. If for any reason you are unable to attend a pre-arranged site visit you should notify the Inspectorate immediately.

FINALLY

Once the site visit is concluded the Inspector will prepare his decision and a formal letter will be sent to the appellant and the Council subsequently.

The Inspectorate is always endeavouring to speed up the process and a decision may be forthcoming very soon after the site visit. This does not mean that the Inspector has made a snap decision. Remember he will have had your appeal documents for some time and is charged with ensuring he has all necessary information before deciding on the case.

The site visit may be accompanied by a representative of either party or unaccompanied if the site can be properly inspected from a public vantage point. In no circumstances will the Inspector conduct a site visit accompanied by only one party.

WRITTEN REPRESENTATIONS

HEARING APPEALS

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