The figure of 3400 new homes is yet to be found 'sound' within the Council's Planning Strategy.

We therefore maintain our long-standing objection that a requirement of 3,400 dwellings between 2011 and 2028 cannot be substantiated.

The level of housing contained in the Local Plan Strategy is based upon that which the Council can deliver and is not underpinned by evidence as required by the NPPF.

The NPPF is clear in respect of the way in which Local Authorities should plan for new housing. Paragraph 14 places a presumption in favour of sustainable development at the heart of plan-making, giving clear guidance that Local Authorities should seek positive opportunities to meet the objectively assessed housing need. The robust method when determining a localised housing target is to identify need in the first instance, and then assess what level of the need can be met to provide the plan with flexibility but without adverse impact. In contrast, the Council's provision appears to have been derived through the reverse procedure, with a predicted achievable level of housing underpinning the target.

The submission DPD seeks to deliver an unjustified and inadequate level of housing and therefore is inconsistent with National Policy and not legally compliant. Until such time as the Planning Strategy has been found sound and a suitable housing target has been established the plan fails to meet the test of being 'justified' and 'effective' and therefore must be 'unsound'.

Further to this, the housing provision within the Local Plan strategy should be viewed as a minimum.

Our overall conclusion is that the Council has proceeded to the publication stage too prematurely ahead of the adoption of a sound strategic plan. To make the DPD robust greater evidence is required to justify excluding suitable and deliverable sites such as our client's land at Breadsell Lane.