Paragraph 14 of the NPPF states that there is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision-taking. For plan-making this means that LPAs should positively seek opportunities to meet the development needs of their area with sufficient flexibility to adapt to rapid change, unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits or conflict with specific policies in the NPPF.

Further to this, paragraph 52 states that the supply of new homes can sometimes be best achieved through planning for larger scale development, such as new settlements or extensions to existing villages and towns that follow the principles of Garden Cities.

In essence, we consider that the cumulative adverse impact of developing lots of smaller sites significantly outweighs any adverse impact of developing Breadsell Lane.

The sites proposed within the submission Plan have an over reliance on greenfield land in urban areas, which play a vastly more important community and environmental role than surplus agricultural land at Breadsell Lane. Urban greenfield areas are finite resources that form important components of a wider green infrastructure network and the setting of built up areas.

Further adverse impact will arise in respect of the loss of recreation ground land and playing fields, which are to the detriment of the health and well being of residents of the Borough. No commentary is provided in the submission Plan in respect of Sport England's views on loss of playing fields or what efforts have been made by the Council to bring these back into a viable community use.

There are also proposed sites that have the potential to adversely impact upon important Heritage Assets.

The cumulative impact of building on many constrained sites results in far greater harm than that of building on former agricultural land at Breadsell Lane. For this reasons we consider that the DPD is based on the least appropriate strategy when considered against the reasonable alternatives, and therefore fails the test of being 'justified'. The plan is therefore unsound.

The substitution of the most constrained sites, in favour of the allocation of land at Breadsell Lane for housing could potentially remedy this position.