It is clear that the submitted Local Plan is unsound, and modifications to it are necessary such that is capable of being found sound.

In order for the Local Plan to be capable of being sound, as per the NPPF, it must contain strategic policies that address a minimum of 15 years from adoption. Such strategic policies should ensure development needs over a minimum of 15 years will be met, as a minimum.

The submitted Local Plan clearly fails to meet this express requirement of the NPPF.

MM10 proposes the introduction of a new policy (Policy MG06) which seek to resolve this flaw in the submitted Local Plan by requiring an immediate review of the Plan upon its adoption.

It should be noted that it is a substantial defect in the submitted Local Plan that the introduction of Policy MG06 seeks to address. The NPPF does not suggest that there are circumstances in which a Plan may address a shorter period than 15 years, and places great emphasis on ensuring development needs are met in full. As such, we consider it critical that the policy is effective and will ensure development needs do not go unmet.

Whilst we support the inclusion of Policy MG06 as a pragmatic response to addressing this issue, we consider that it is critical that the policy ensures that a review of the Local Plan is progressed and adopted. We do not consider that, as currently proposed to be worded, Policy MG06 achieves this.

Additional supporting text should be included which makes reference to the basis on which sites will be identified for allocation as part of the review. This should refer to the sites within the SHLAA that were assessed as being suitable, available and achievable but which were rejected on questionable grounds, including due to their location within the Green Belt.

We have concerns that there are no safeguards in place to guarantee the review of the Plan being undertaken within the proposed timescales, or at all. As such, and in order to ensure the proposed approach will be effective, suitable wording should be incorporated which states that failure to review the Plan within the specified timescales will be deemed a significant factor in determining whether Very Special Circumstances exist for planning applications on sites within the Green Belt.

We also note that Policy MG06 does not specify a timeframe for adoption of the Local Plan review, and there is nothing within the suggested wording that would require it to be progressed beyond submission.
In addition, and whilst we agree it is necessary to specify a timeframe of 28 months for a Local Plan review to be submitted, we question whether this is achievable without Policy MG06 providing a clearer steer.

Appendix V to the Local Plan Final Sustainability Appraisal Report (January 2019) contains a list of ‘village omission sites’ which identifies whether any should be taken forward for further analysis. These sites were identified as deliverable or developable, but not considered further as potential allocations as they did not conform to the Plan’s spatial strategy.

The inclusion of suitable wording would set out the basis on which sites will be identified for allocation within the review, and provide a clear steer to decision makers when approaching the site allocation process. This will also enable the ambitious timescales for the review to be met, given such sites have already been assessed in detail.
Additional wording should also be included within Policy MG06 which states that failure to undertake the review within the specific timescales would be deemed a significant factor in determining whether Very Special Circumstances exist for proposed development sites within the Green Belt.

Additional supporting text should be included which refers to omission sites, assessed as suitable, available and achievable within the Plan’s evidence base as the starting point for identifying site allocations.