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Advice to Norfolk County Council

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Enquiry

From
Norfolk County Council
Date advice given
9 April 2021
Enquiry type
Email

(a) Word Limit In making the our representation / registering our submission online – is there any word limit at this stage? On previous NSIPs where the County Council has registered comments there has not been any word limit as far as I’m aware and the County Council has “cut and paste” those comments agreed through our relevant Committee process; In making representations on the above Blofield to Burlingham scheme there was a suggestion from the Planning Inspectorate (PINS) that there is an upper word limit on the online registration Form of 500 words. As a statutory Consultee with a number of statutory roles, including Highway Authority; and Lead Local Flood Authority, it is not feasible to make a short (500 word) representation given the detailed technical / statutory nature of our comments. Therefore please could you confirm whether there are any word limits in registering our comments. (b) Representations made The County Council has made representations to the A47 Blofield to Burlingham Scheme and has received two ID Numbers. I believe the first was in relation to representations which were made direct to PINS (see PDF attached); and the second was in relation to a Summary of the County Council’s representation, which were made on the online Registration Form. Please can you confirm which is the valid ID Number - we don’t need two. (c) Local Impact Report (LIR) I understand from previous NSIPs the County Council has been involved with that the preparation of a Local Impact Report is not a requirement, although LAs are encouraged to produce and submit such evidence normally at deadline 1 in the Examination Process as set out in the Rule 6 letter. Given the complexity in responding to the submitted DCO documentation at the registration stage and the uncertainty regarding the word limit (as outlined above), is there any opportunity of providing further detailed evidence to the Examining Authority through the LIR? In other words can the LA at the Registration stage simply indicate that it is an “interested Party” with a number of detailed issues it would like addressing through the DCO/Examination process – and then provide the detailed evidence through the LIR. This would give a LA significantly more time to prepare its response to the DCO over and above the 28 days we have to register comments following submission. I’d welcome your advice and comments.

Advice given

Representations made Firstly, I confirm that Norfolk County Council (NCC) has registered successfully and submitted its Relevant Representation (RR) for the A47 Blofield to North Burlingham Dualling scheme. It will appear as part of the suite of RRs when published. As we only register each organisation once, please disregard the reference (redacted) and use (redacted) for future correspondence. Valid RRs must be submitted via the Registration and Relevant Representation form (either paper or electronically online). However, we understand that Statutory Consultees are likely to have more complex RRs and sometimes prefer to submit their RRs on formally headed letters. In this instance we will append to the formal letter as the RR (for example here) so that it’s content is easier to read, especially when there are sub-headers within the letter. I have therefore appended the original NCC letter to your summary so that the complete submission is contained with one registration (redacted). Word Limit The Inspectorate asks that RRs are ideally kept to a maximum of 500 words as they are initial submissions that should set out the key issues that will later be expanded and backed with evidence, either in written submissions or orally at hearings, once the Examination begins. However, we understand Statutory Consultees (such as local authorities, as the competent authority for various matters) may have lengthier RRs longer than 500 words. Although there is no word limit set for RRs, you may find the RR field on the online form will limit you to a finite number of characters and therefore lengthier RRs are accepted if provided on a letterhead, if the registration has already been completed. In future, I recommend NCC registers through the online form and provides either a summary of its main RR or a brief sentence to say the main submission will be provided in letterhead form via email. Please then email the letter once the registration process has been completed and note you have done this to negate any concern that the process has yet to be completed. If the content of your letter fits in the RR field, you may still wish to provide the letter via email to improve readability. Local Impact Report (LIR) The Examination Timetable will include a deadline for Local Impact Reports (LIRs) quite early in the examination, therefore RRs from local authorities do not need to contain the detailed evidence the LIR will later provide. As advised above, the RR should focus on the key issues. For further information on the production of LIRs, please see the Inspectorate’s Advice note One: https://infrastructure.planninginspectorate.gov.uk/wp-content/uploads/2013/04/Advice-note-1v2.pdf