Object
Background documents
Representation ID: 99514
Received: 16/12/2022
Respondent: Dr L David Ormerod
Legally compliant? No
Sound? No
Duty to co-operate? No
Avoidance of Public Accountability and Inaccuracy of MPA Responses to the Consultation Submissions:
The elicited contributions from the two rounds of "consultee" contributions and from the two rounds of public "commentaries" are reproduced in a variable, abbreviated format in the May 2022 document, the NMWLP Review Statement of Consultation. Given the selective nature of the issues reported, it is surprising how often they are disregarded or misrepresented in the attached MHA commentary. The odd infelicity is of little significance, but this occurs on an unacceptable number of occasions. It is regrettable that such instances have not been edited from the document as it calls into question whether this reflects internal agendas?
It is difficult to be certain of the implications, particularly as the public contributions, in particular are presented in a manner which is particularly difficult to interpret. Action items are usually presented as brief, aggregate comments from which it can often be observed that important critique is omitted. Specific aspects, including such examples, are discussed in greater detail elsewhere. Here. a brief listing is provided limited to discussions of minerals process and of individual site considerations. The principal source (as per MPA) of the action item(s) is stated, with headline subject and page number given. Elsewhere. it is shown that public comments are given far less weight than those of 'official' consultees, and there is little MHA response that can be shown to be directly associated with public submissions. The list presented is not comprehensive as there are undoubtedly missing examples, on a random basis.[see representation 99528 for list]
Immediate problems include the absence of recognition of local public concerns and the failure to recognize recreational public land-use issues. As we shall see later, the NMWLP planning has almost completely ignored the interests of local and regional communities throughout the 13-year history of this Plan. The NMWLP document, 2022, under review, furthermore, has failed to give due recognition and has essentially suppressed the submitted views of 4.500 local citizens who submitted statements that they systematically used the Shouldham Warren area (AOS E and SIL 02) for recreation as an open access site. It will also be shown that worrisome facts that are inconvenient to the MH/\ have been deliberately suppressed.
Soundness test: not effective, not positively prepared, not consistent with national policy.
The Statement of Community Involvement (SCI), Section 2.1.6 inhibits public comment to the two brief "consultation" periods. The section states that public comments and (officer-) comments will be maintained on the County Councils e-planning website. This happened for the first 2018 consultation, but it took 2.5 years for the second 2019 consultation statements to be published, at "five minutes to midnight", and there is no institutional response and no evidence that they have been taken into consideration (e.g. N.C.C Cabinet document. December 10, 2019, M&WLPR - Preferred Options Consultation) in contravention of undertakings under the Statement of Community Involvement. The Local Plan procedures have taken 3 years (including COVID) after the Preferred Options Consultation. Section 2.1.5.4. of the S.C.I. determined that a consultation deadline does not mean that "comments received after the deadline will be ignored. The deadline is the date by which we guarantee we will have not determined the application, and so any comments made in that time will he considered. If you submit comments after the deadline date, but before we have determined the application, we will consider your comments." In fact, N.C.C. insisted on the 'consultation deadline date· as the cut-off point. As the Statement of Community Involvement provides much of the structure of the Local Plan processes, it is important that the County Council modify this foundation document to provide full and systematic assessment of public views, including public meetings involving all adjacent village and town communities at an early opportunity. This will be discussed further in a separate review of AOS-E experience. The SCI is presently due for revision under the Norfolk Minerals and Waste Development Plan, October 2022.