We do not favour the prioritisation of brownfield land over greenfield land. This is not a Framework compliant approach. Given the considerable amount of housing required across the plan area it is necessary for both greenfield and brownfield sites to be released at the same time. Indeed, the greenfield/Green Belt sites are likely to serve different areas of the housing market, given their geographical detachment in the large parts of the Growth Network and will provide a different type of development sites.

In terms of a discount rate it is now evident that the Growth Network has not delivered houses as expected. It is, therefore, our clear view that there should be an increase in the discount rate that should result in the overall housing requirement being increased relatively significantly. An alternative would be to over allocate and provide reserve sites in line with the LPEG report. This would see a 20% increase in allocations through the identification of reserved sites that could be drawn upon where a 5 year supply cannot be demonstrated.

We make no comment at this stage about proposals for high density allocations within the strategic centres other than to say that market research should be carried out to ensure there is both demand and an appetite from the housebuilding industry to provide this type of product.