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. Reliance on brownfield development will need to be significantly reduced. It is already acknowledged that at least 22,000 to 25,000 new dwellings may have to be allocated on greenfield/Green Belt sites. As referred to in above, we are of a view that the actual requirement is higher than this as the housing requirements should be in excess of the SHMA housing requirement which needs to be adjusted to take account of affordable housing needs. In addition, the housing requirements should exceed the objectively assessed housing needs figure as not all housing sites will deliver as expected. Furthermore, there is now evidence that a large number of the former employment sites allocated for residential development by the adopted Core Strategy are returning to employment use and are no longer available. Significant reliance will need to be placed on greenfield sites.

The brownfield first requirement is 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.