Belfast Local Development Plan (LDP) 2035 - Draft Plan Strategy - Counter Representations

Closed 26 Apr 2019

Opened 1 Mar 2019


We consulted on the draft Plan Strategy (dPS) as part of an ongoing process for creating the Belfast Local Development Plan 2035. A number of representations, which we have now published, were received during the public statutory consultation process which ended at 5pm on Thursday 15 November 2018.

Hard copies of the representations received on the dPS are available for inspection during normal office hours at:

Belfast Planning Service
Belfast City Council
Cecil Ward Building
4-10 Linenhall Street

The representations can also be viewed on the Council’s website at

Counter Representations

Following publication of the representations received on the dPS, there is now the opportunity for the submission of counter representations. The consultation period for the submission of counter representations runs from 12 noon on Friday 1 March 2019 until 12 noon on Friday 26 April 2019.

Counter representations may only be made in relation to a site specific policy representation seeking a change to the dPS and should indicate the reasons for doing so in terms of soundness and sustainability of the dPS.

Any person may make a counter representation, but must not propose alternative sites or any further changes to the dPS and are without a right of hearing at Independent Examination (IE). Counter representations of this nature or those supporting a site specific policy representation will not be considered.

A “site specific policy representation” means any representation which seeks to change a development plan document (DPD) (in this case, the dPS) by:

  1. adding a site specific policy to the DPD; or
  2. altering or deleting any site specific policy in the DPD.

A “site specific policy” means a policy in a DPD which identifies a site for a particular use or development.

The dPS does not include site specific policies as these are dealt with at the next stage of the LDP process, which is the preparation of the Local Policies Plan (LPP). However, a number of representations received in response to the public consultation make reference to specific sites and proposed development or uses. Any counter representation should clearly state the reference number of the representation to which it relates.

Submitting a Counter Representation

Counter representations on site specific policy representations must be received by Belfast Planning Service by 12 noon on Friday 26 April 2019. Any counter representation received after this time will not be considered.

Counter representations can be submitted:

Although we have provided a downloadable version of this consultation response form, we would encourage you to respond via the online survey.


The relevant documents are available, on request, in alternative formats - Braille, audio, large print, easy read. The council will also consider requests to produce it in other languages. If you require the documents in these or other formats please contact us:

Belfast Planning Service
Belfast City Council
Cecil Ward Building
4-10 Linenhall Street

Telephone:  028 9032 0202, ext 2255


Why we are consulting

We are consulting in accordance with Regulations 17 and 18 of the Planning (Local Development Plan) Regulations (Northern Ireland) 2015. These regulations deal with the publicity and availability of representations on a DPD and the requirements placed on the Council for the handling and consideration of any counter representations received during the public consultation on site specific policy representations.

Counter representations submitted as part of this consultation will inform the ongoing process for creating the Belfast Local Development Plan 2035. They will be considered at the IE into the dPS. The IE will be conducted by the Planning Appeals Commission or other independent body to determine whether the dPS satisfies certain legislative requirements and whether it is ‘sound’. In carrying out the IE, a series of soundness tests will be applied. Information on the ‘Tests of Soundness’ can be found in the Department for Infrastructure’s Development Plan Practice Note (DPPN) 06 (available from

Before Completing Counter Representation Form

Before you complete the online form to submit a counter-representation you will need to ensure you have the following information to hand:

  • The reference for the response that you wish to comment on.  It should be in the format DPS-X-XX-X;
  • If you submitted a response to the draft Plan Strategy, the reference for your response and a short summary of the issues you raised.  The reference should be in the format DPS-X-XX-X;
  • If this is the not the first counter representation you have submitted via this online form, the Response ID assigned to your first response.  It should include both numbers and letters and be in the format 'ANON-XXXX-XXXX-X'  By quoting this in subsequent responses this will mean that certain information you provide in your first response will not need to be repeated.


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