VALP Main Modifications
Representation ID: 2985
Respondent: Arnold White Estates
Agent: Arrow Planning Ltd
Legally compliant? Yes
The calculation of the 5-year Housing Land Supply shown in Table 9 is incorrect because:
Past completions in the Plan period have all been 'persistent under delivery' so that a buffer of
20% should be applied.
The 'Liverpool method' is inappropriate PPG 031 Reference ID: 68-031-20190722, requires
the 'Sedgefield method'
The Modification to Table 9 shows that the supply is 4.46 years, thus the Plan is unsound not being
'justified' or 'consistent with national policy.
Table 9 pp63/64 Housing land supply for 1st April 2018 to 31st March 2023 should be as follows
(Please see attached full representation)
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.