Better Presentation of Evidence in Chief Guidance
A. Proofs of Evidence

- Proofs of evidence should be as concise as possible avoiding
repetition and verbosity.
- Every effort should be made by the Appellant/Applicant/Objector
and the LPA to agree factual information such as the site description,
description of surrounding area, planning history, data and statistics
etc, as soon as possible.
- Where it is necessary to set out facts in detail, they
should focus on what is really necessary for the matter in hand and
avoid including unnecessary material. Details such as site description
and planning history, if not in an agreed statement, could usually be
set out in appendices with only a succinct statement of the crucial
facts in the proof itself.
- Conciseness is particularly necessary in the case of proofs
for Development Plan Inquiries. They are mostly concerned with the principles
of the generic use of areas of land and rarely with the detail of specific
development proposals. Thus evidence as to the merits of proposed schemes
of development is rarely appropriate, though from time to time evidence
may involve matters of detail such as calculations as to the satisfaction
of a structure plan housing remit.
- The text of national and regional guidance should not be
repeated in the text of the proof, nor should even a summary of them
be set out. The parties and the Inspector may be assumed to have access
to national and regional guidance such as PPGs which need not be included
in the appendices. Relevant local policies are best presented in the
form of extracts which should be included in the appendices and normally
quoted only as necessary in the proof.
- Where in the text of the proof a point is made in reliance
upon a document (whether or not that document is included in the appendices),
the page and paragraph number in that document should always be identified.
- A section at the end of the proof setting out conclusions
is only helpful if it genuinely sets conclusions which flow from the
preceding text. "Conclusions" should not be used to include
new points.
- Proofs should have their pages and paragraphs numbered.
Supplementary Proofs
The rules do not provide for supplementary proofs, and as a general aim
all the witness's evidence should be included in the proof served three
weeks prior to the inquiry. However, it is recognised that in some circumstances,
a party finds (for example upon reading another party's evidence) that
an additional matter has to be covered. In such circumstances, any supplementary
proof should comply so far as possible with these guidelines and should
be provided to all other parties without delay. Supplementary proofs (i.e.
containing supplementary material) should be kept separate from summary
proofs required under the rules (which should only summarise what is in
the proof itself: see below).

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