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R (Bond) v Vale of White Horse DC: Planning Court confirms LPAs can correct adopted policies map mistakes outside local plan process; map is LDD, not DPD (England)

Published on: 20 November 2019

Published by a LexisNexis Planning expert
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R (on the application of Bond) v Vale of White Horse District Council [2019] EWHC 3080 (Admin)

What are the practical implications of this case?

The Planning Court’s ruling is tightly tied to the particular facts. The issue arose because a change to the green belt policy within a local plan—introduced to mirror the recommendations of an inspector undertaking an independent examination—was not translated onto the adopted proposals map. The map failed to reflect the inspector-led modification carried through the plan-making process, leaving a mismatch between policy text and mapping outputs. That said, the judgment usefully reiterates that an adopted policies map is not a development plan document for the purposes of the Planning and Compulsory Purchase Act 2004 (PCPA 2004). A policies map, once adopted, is a local development document and sits outside the local plan itself. Moreover, a policies map only needs to be lodged as a prescribed document with a draft local plan sent to the Secretary of State where the accompanying local plan would alter it. Here, the local plan policy was accurate and required no modification. The problem was simply a factual mistake on the related adopted policies map. In those circumstances, the court did...

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