VALP Main Modifications
Representation ID: 2980
Respondent: Arnold White Estates
Agent: Arrow Planning Ltd
Legally compliant? Yes
The modified but low housing numbers in the Plan can only be justified if the Plan includes a
commitment for an early review. That linkage is essential because the Plan has been prepared under
NPPF 2012 which was allowed by Government as a 'stop-gap' measure. Full housing provision for
the VALP would be some 48,000 homes over the Plan period using the 'standard method' so even
the Plan is providing 30,233 homes that is some 18,000 homes short. The 'early review' commitment
is now proposed for deletion so that Plan, based on the numbers now proposed, is unsound not being
effective or consistent with national policy.
As it stands the housing numbers are unsound. Either the 'early' Review is re-established (and the
consequence of not doing so reflected in a new Policy) or the housing numbers and allocations
should be increased significantly increased thus making the current version of the Plan unsound.
On behalf of my client Arnold White Estates Ltd I attach our representations on the forms provided. I draw your attention to the difficulty I have found in making these submissions. The Schedule of Modifications does not show the relevant page numbers in the Plan as proposed to be modified, which means cross-referencing is very difficult. For example, in the Modifications Schedule MM027 shows a modification to para 4.7 at p62. The Modified Plan shows this as para 4.9 at p67. The Modification Schedule and the Modified Plan should have the same page and paragraph numbers. Also, for example, there are two Policies D2. In the forms I have sought to group linked Main Modifications on one form where a combined response is then provided. Where necessary I have inserted a blank page to accommodate text that would not fit within the box provided. I trust all of my text will be captured.