We do not consider that the submission DPD is 'flexible'.

Paragraph 14 of the NPPF requires Council's Local Plan to be able to flexibly adapt to rapid change. The site allocations currently proposed in the plan are required to implement the housing provision to be set out in the Local Planning Strategy. However, there are no mechanisms put in place within the submission DPD to allow the Council to respond to the non-delivery of sites. In this respect, there continues to be a reliance on historic Local Plan allocations that have been identified to provide housing in the past and sites that have been granted planning permission but have never implemented.

This non-delivery has been a regular occurrence during strong economic periods, so even greater uncertainty remains during in a period of weakness in the national economy.

The failure to provide a 'flexible' Plan renders the submission DPD 'ineffective' and therefore unsound.

We consider that the inclusion of a housing allocation for land at Breadsell Lane as either a reserve site or as an allocation in the latter stages of the plan would remedy these concerns and make the DPD effective.