We are content with four of the five Core Strategy provisions and sustainability principles, but the fourth bullet point "brownfield first" is no longer appropriate. By necessity the reliance on brownfield development will need to be significantly reduced and it is already acknowledged that at least 22,000 to 25,000 new dwellings and 300 hectares of employment land may have to be allocated on greenfield/Green Belt sites. As referred to in above, we are of a view that the number of dwellings should actually be higher than this, which would further emphasise the role of greenfield sites.

The brownfield first requirement is also not in accordance with the guidance in the Framework. The Framework identifies 12 Core Planning Principles at paragraph 17. Here the Framework seeks to "encourage" the effective use of brownfield land. It does not, however, make it sequentially preferable to greenfield sites. The Framework acknowledges that there are instances where the development of greenfield land is preferable to brownfield sites for a variety of different reasons. This should be reflected in the emerging Plan.

It is also important to draw a distinction between the concept of 'brownfield first' approach when considering whether urban capacity exists to meet the development needs identified, and an attempt to rank brownfield and greenfield sites when it has been identified that a significant volume of greenfield sites are needed to meet the development needs. It was suggested at the public consultation event I attended that phasing of greenfield sites was being considered. This would be wholly inappropriate. Greenfield sites will represent such a large number of dwellings that leaving them to be considered for another day would undermine their delivery. The role of greenfield sites is also not only important in terms of overall numbers, but also providing more certainty in delivery in the short term. Currently we think the 5 year housing land supply positions presented for the BCAs are overly optimistic and greenfield sites will be needed if sufficient delivery is going to be achieved in the early years of the plan to address the existing backlog and more generally the increased annual requirement.