Please carefully read this guidance before making your representation.

We want to make it as easy as possible for you to give us feedback about our revised Plan. We also want to help make sure that your feedback meets the relevant criteria so that your views are in the best position to be fully considered by the independent Planning Inspector. 

The technical and specific nature of the consultation means that the most effective way you can respond is by completing our dedicated survey. We will need to ask some specific questions, but don’t worry, there is also the opportunity to raise any broad or general questions or concerns about the Plan as part of our survey, too.

Guidance on making your representation

We have published Warrington’s ‘Updated Proposed Submission Version’, or draft, Local Plan for consultation. We are now seeking your views on the Plan.

The consultation is open for six weeks, from Monday 4 October, until 5pm on Monday 15 November 2021.

How the Local Plan has been prepared

The preparation of our draft Local Plan has been informed by:

  • national policy and legislation
  • listening and responding to feedback from the previous consultation stages
  • evidence gathering about our Borough now and in the future
  • ongoing discussions with neighbouring authorities
  • engagement with key organisations such as Homes England, Highways England, the Environment Agency and infrastructure providers

What are we consulting on now?

This is the final consultation before we submit the Local Plan to the Planning Inspectorate, who will examine it on behalf of the Government.

This consultation presents the opportunity to comment on the proposed policy content of the draft Local Plan, with specifically-focused questions.

The questions relate to whether the Plan complies with legal requirements, the ‘duty to cooperate’ and meets the ‘tests of soundness’. These are the key issues that the independent Inspector will consider when assessing the Local Plan and they are explained in detail below.

We have framed the consultation in this way, to meet the requirements of the Planning Inspectorate and to ensure that your representation on the Local Plan is as effective as possible.

Legal Compliance and Duty to Co-operate

The Inspector will first check that the Plan meets the legal requirements under section 20(5) (a) and the duty to co-operate under section 20(5) (c) of the Planning and Compulsory Purchase Act 2004 before moving on to test for soundness.

Legal compliance considerations

You should consider the following before making a representation on legal compliance:

  • The Plan should be included in the current Local Development Scheme (LDS) and the key stages should have been followed. The LDS is effectively a programme of work prepared by the Council, setting out the plans it proposes to produce and their key stages of production. If the Plan is not in the current LDS it should not have been published for representations. The Council’s latest LDS was approved in September 2021 and can be viewed on our local development scheme page.
  • The process of community involvement for the Plan should be in general accordance with the Council’s Statement of Community Involvement (SCI). The SCI sets out the Council’s strategy for involving the community in the preparation and revision of planning documents (including Local Plans) and the consideration of planning applications. The Council’s SCI was updated in December 2020.
  • The Council is required to provide a Sustainability Appraisal (SA) Report when it publishes a plan. This should identify the process by which the Sustainability Appraisal has been carried out, and the baseline information used to inform the process and the outcomes of that process. Sustainability Appraisal is a tool for appraising policies to ensure they reflect social, environmental, and economic factors. The Council’s updated SA report can be viewed on our Local Plan page.
  • The Plan should comply with all other relevant requirements of the Planning and Compulsory Purchase Act 2004 and the Town and Country Planning (Local Planning) (England) Regulations 2012 as amended. On publication, the Council must publish the documents prescribed in the Regulations, and make them available at its principal offices and on its website. The Council must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified.
Duty to cooperate considerations

You should consider the following before making a representation on compliance with the duty to co-operate:

  • Section 33A of the Planning and Compulsory Purchase Act 2004 requires the Council to engage constructively, actively and on an ongoing basis with neighbouring authorities and certain other bodies over strategic matters during the preparation of the Plan.  The Council will be expected to provide evidence of how it has complied with the duty. The Council’s Duty to Co-operate Statement can be viewed on our Local Plan page.
  • Non-compliance with the duty to co-operate cannot be rectified after the submission of the Plan. Therefore the Inspector has no power to recommend modifications in this regard.  Where the duty has not been complied with, the Inspector cannot recommend adoption of the Plan.


The tests of soundness are set out in paragraph 35 of the National Planning Policy Framework (NPPF). 

Plans are sound if they are:

  • 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 authorities 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 in the NPPF.

If you are seeking a change to the Plan

If you wish to make a representation seeking a change, known as a ‘modification’, to the Plan or part of the Plan you should first set out clearly in what way you consider the plan or part of the Plan is legally non-compliant or unsound, having regard as appropriate to the soundness criteria set out above. Your representation should be supported by evidence wherever possible. It will be helpful if you also say precisely how you think the Plan should be modified.

You should provide succinctly all the evidence and supporting information necessary to support your representation and your suggested modification. You should not assume that you will have a further opportunity to make submissions. Any further submissions after the Plan has been submitted for examination may only be made if invited by the Inspector, based on the matters and issues they identify.

If you think the content of the Plan is not sound because it does not include a policy on a particular issue, you should go through the following steps before making representations:

  • Is the issue with which you are concerned already covered specifically by national planning policy?
  • Is the issue with which you are concerned already covered by another policy in this Plan?
  • If the policy is not covered elsewhere, in what way is the plan unsound without the Policy?
  • If the Plan is unsound without the policy, what should the policy say?

Making Representations as a Group

here groups or individuals share a common view on the Plan, it would be very helpful if they would make a single representation which represents that view, rather a large number of separate representations repeating the same points.  In such cases the group should indicate how many people it is representing and how the representation has been authorised.

Examination in Public

Please consider carefully how you would like your representation to be dealt with in the examination: whether you are content to rely on your written representation, or whether you wish to take part in hearing session(s). Only representors who are seeking a change to the Plan have a right to be heard at the hearing session(s), if they so request. In considering this, please note that written and oral representations carry the same weight and will be given equal consideration in the examination process.

Further information on the Examination Process is available from the Planning Inspectorate.

Completing the Online Representation Form

Format of the online survey

The first page of the survey is an introduction and welcomes you to the consultation. Useful links to the draft Plan and guidance on the consultation are provided on this page. You are encouraged to read these documents before completing the Online Representation Form.

Part A - your details

​​The second page is compulsory. This is ‘About You’ and is legally required for a response to count.  You are required to complete this section before you can carry on.

Part B - your representation

By clicking ‘next’ you will commence to the Representation Form. This form shows a list of sections and policies that are contained within the Draft Local Plan.  You can respond to whichever sections and policies you are interested in.

If your comments do not relate to any of the sections or policies listed and you wish to comment overall on the Local Plan Strategy then please select ‘draft Local Plan as a whole’. Where applicable you will be asked to list paragraph and policy sub-numbers in the Plan.

For each representation form there are eight specifically-focused questions. These relate to legal compliance and the ‘Tests of Soundness’.

  • For some questions a box is available to type in your answers
  • Some questions ask you to click on a circle, in a box or a drop down list to select your answer(s)
  • Other questions will require one answer, for others there are multiple answers.
  • You can also upload documents to support your response.

Questions are framed in this way to meet the requirements of the Planning Inspectorate.

You can submit up to 50 Representation Forms. At the end of each form you can select to complete another form or simply complete the rest of the survey.

Part C - about you

Part C Customer 'About You' questionnaire

Demographic information is captured in the last section. This is the collection of information about the characteristics of people such as their age, disability, gender, ethnicity, sexual orientation, religion or belief. Effective equality monitoring is a key element in helping the Council meet its legal obligations.

Submitting a response

You do not have to complete the survey in one go. Throughout the survey there is the option to ‘save and continue’. If you choose ‘save and continue’ you will be asked to provide an email address – and then will be emailed a link. When you to go back to it, all you have to do is click on the link.

There is no ‘time-out’ on the survey so your response should remain accessible as long as you have the survey open in your browser.

If you don’t save and then close your browser, this could then cause you to lose the response when you re-open the browser, so the save and continue (above) function should be used if you cannot complete the survey in one go.

On completion of the survey please select the ‘submit’ button. If you have provided an email address you will receive a copy of your full response form and a unique id number. You should retain this id number for future reference.

Should you encounter any problems accessing or completing the online survey then please email

Responding in other formats

We will be making paper copies of the standard response form available in all the libraries across the Borough, as well as at the Council’s Time Square office. Copies can also be sent out if you call the Planning Policy & Programmes Team on 01925 442826.

The questions on the paper form are the same as the online form (see above guidance).

An editable PDF of the response form is also available from the Council on request.

Please use a separate Part B form for each representation and ensure that one copy of Part A (Personal Details) is securely attached.  Any additional paper used must clearly state which question it relates to.

If you require the response form, or the draft Plan, in another language or format including large print, Braille, audio or British Sign Language or simply require assistance in completing it please call 01925 442826 or email

Representations can also be made by:

  • Email to
  • Post to Local Plan, Planning Policy and Programmes, Growth Directorate, Warrington Borough Council, East annexe, Town Hall, Sankey Street,  Warrington WA1 1HU
  • Hand delivery to the Reception at the Council’s 1 Time Square Offices from 9am – 5pm Monday to Friday
Data protection

In line with General Data Protection Regulations, your details are stored on a secure system and are used only for the purposes of consultation for the Local Plan and associated documents.

Your response together with your name will be available to view publicly when we report on the outcome of the consultation. All other personal information, such as your telephone number, street name and number and e-mail address will not be published. We may however be required to provide this information to the Planning Inspectorate to ensure that you can be contacted and take part in the examination if required.

You can read more about how we use your information on our privacy policy page.