VALP Main Modifications
Representation ID: 2984
Respondent: Arnold White Estates
Agent: Arrow Planning Ltd
Legally compliant? Yes
In response to overall housing numbers (MM001, 002, 003, 010) breaking the link between
what are low housing numbers with the commitment for an 'early review' is unsound (NPPF
2012 para 182 'justified', 'consistent with national policy').
A Plan based on maintaining that link could only be sound if the early Review was a
The reason for this change is the administrative inconvenience of the abolition of AVDC and
its replacement Buckinghamshire Council from April 2020. This is not significant reason to
change 'early' to '5 years from adoption'
MM026, and consequent changes
The 'early review' commitment should be reintroduced into Policy S9 by the following amendment
Irrespective of the above criteria, the Plan will be urgently reviewed, not least to reflect the
need for higher housing numbers to reach the stage of another Submitted Plan (currently
Regulation 22) within 2 years of the adoption of this Plan.
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.