Guidance Notes for Comments

Guidance notes for comments on the Places for Everyone proposed modifications consultation.


GMCA on behalf of Bolton, Bury, Manchester, Oldham, Rochdale, Salford, Tameside, Trafford and Wigan, is preparing Places for Everyone: Joint Development Plan Document (PfE). The examination of PfE began in 2022 following submission of the plan to the Secretary of State on 14 February 2022. Hearing sessions were held between November 2022 and July 2023. 

Through the examination process, some changes to PfE (referred to as ‘modifications’) have been identified. It is now necessary to consult on the Main Modifications and Policies Map change(s) (i.e. those that are necessary to make the plan sound and / or legally compliant), associated Integrated Assessment (including a Sustainability Appraisal) and Habitat Regulations Assessment and Additional Modifications (i.e. minor changes to correct errors or improve clarity). 

What the Inspectors will consider

Comments should only relate to the modifications to the PfE plan.This is not an opportunity to make comments on any other parts of the plan.

The Inspectors will only consider comments received in response to the Main Modifications and Policies Map change(s). The nine PfE councils will consider comments relating to the Additional Modifications.

Comments can be submitted in more than one way, but don’t respond with the same comments more than once. Our preferred method is by our online consultation portal and information is available on the portal to help you respond.

However, we have also produced a downloadable form for those who would prefer to respond in that way. The form is in two parts – Part A for personal details and Part B for your comments. Additional sheets may be used to provide additional information. Complete a separate Part B sheet for each set of comments you wish to make.

Guidance on the questions

Question 1 - Part A – Personal / Agent Details

It is not possible for comments to be considered anonymously. Comments and names will be published on the GMCA’s website and / or the examination website. We need you to tell us that you agree that your response will be published and you name and details passed to the planning inspectors, and that you have read and understood our privacy notice on the GMCA website.

Supply an email address if you have one as it will allow us to contact you electronically which is our preferred method. Also remember to update us with any changes to your contact details in the future.

Question 2 - Are you aged 13 and over?

Due to data protection laws we cannot store and keep details of anyone under the age of 13. Therefore we need to ask if you are aged 13 and over. If you are aged under 13 and would like to make comments then do so with the details of your carer, parent or guardian (with their permission).

Question 3 - Part B – Your consultation response

Specify which section of the proposed Main Modifications and / or Policies Map change(s) your comment relates to. Each proposed modification has a reference number which can be found in the Modifications Schedules and in the Composite Plan. We need you to tell us if you think that the modification is needed to make the plan sound and / or legally complaint, provide reasons for why you may agree or disagree with it, and whether the wording identified is effective.

Soundness is explained in paragraph 35 of the National Planning Policy Framework (NPPF). The Inspectors have to be satisfied that the Plan is positively prepared, justified, effective and consistent with national policy as follows:

Positively prepared

This means that the plan should, as a minimum, provide a strategy which seeks to meet objectively assessed needs, and is informed by agreement with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.


The plan should be an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence.


The plan should be deliverable over its 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.

Consistent with national policy

The plan should enable the delivery of sustainable development in accordance with the policies of the NPPF and other statements of national planning policy, where relevant.

Points of legality include compliance with the Town and Country Planning (Local Planning) (England) Regulations 2012 (the Regulations) and the preparation of a Sustainability Appraisal (SA) /Integrated Assessment. A Sustainability Appraisal is a tool for appraising the plan to ensure it reflects social, environmental and economic factors.

Question 4 - Part B – Your consultation response

Specify which section of the proposed Additional Modifications your comments relate to. Each proposed modification has a reference number which can be found in the Additional Modifications Schedule and in the Composite Plan.

The inspectors will not consider any comments relating to the additional modifications given such changes do not relate to soundness or legal compliance.

General advice

If you wish to make comments seeking an amendment to a proposed Main  Modification and / or Policies Map change(s) you should set out clearly in what way you consider the modifications are either necessary or not to make the plan sound and/legally compliant and whether they would be effective in achieving this and if not how the wording could be changed to make it more effective.

If you consider it necessary, you can attach supporting information to support your comments.

Where groups or individuals share a common view on the modifications, it would be very helpful to make a single submission which represents that view, rather than a large number of separate submissions repeating the same points. In such cases the group should indicate who it is representing and how the comments have been authorised.

All comments received relating to the Main Modifications will be submitted to and considered by the Planning Inspectors. The Planning Inspectors will consider the representations made on the Main Modifications and consequential changes to the policies map before finalising their examination report and determining whether to recommend that Main Modifications are made so that the plan is capable of adoption. 

Further hearing sessions will not usually be held, unless the Inspectors consider them essential to deal with substantial issues raised in the representations, or to ensure fairness. The nine PfE councils will consider the comment on the additional modifications. 

You need to sign and date the form.

How to submit a comment

You can submit comments online, by email or post. All comments must be submitted no later than 23:59pm on 6 December 2023.

submit a comment online