The housing requirement on which the Development and Site Allocation (DaSA) Local Plan is predicated is based on the Core Strategy (CS) which was approved in 2014 but is based on earlier data, in particular the ONS population predictions for 2011. Planning Practice Guidance is quite clear that the ONS 2014 projections are those that should be used to assess housing need. The CS Inspector having considered evidence from the RTPI Research Report No1 (Jan 2014) advised that if the economy improved significantly it could lead to higher levels of housing need. The economy has improved and the publication of the 2014 ONS population data together with the Governments guidance that this should now form the basis of housing need assessment has significantly undermined the CS. The CS Inspector's conclusion that the CS was sound in 2014 was based on the premise that the Council would keep this matter under review. This has not happened and consequently it leads to the finding that the DaSA cannot be found sound in respect of housing need because the failure to review the housing requirement leads to an ineffective plan which is not justified (see Objective 1 of the SA) and does not comply with national policy as set out in NPPF.

Para 8.17 Contains an admission that the annualised housing requirement has not been achieved and that housing delivery is unlikely to catch up on present projections. Whilst a margin of overprovision is stated as being appropriate this is not apparent in Policy OVE1 which merely repeats the CS requirement which is inadequate for the reasons stated above. Whilst the words "at least" are noted in policy OVE1 this is inadequate because it is not backed up by additional allocations or policy wording to deal with the current situation where housing 5 year land supply is significantly deficient (3.44 years at April 2018) and there is a persistent under supply of dwellings being built.

The Council have admitted to a persistent under supply of housing and whilst the DaSA contains site allocations these have been in the public domain for a number of years and have not come forward for development in an area where the Council has admitted that planning permissions would have to be granted on unallocated sites because of the failure to be able to demonstrate a 5 year housing supply. This is evidence that the Council's choice of sites for allocation is unsustainable. Consequently in accordance with NPPF 2012 para 47 an appropriate increase in net additional homes over the period to 2028 is 20% taking the total in policy OVE1 from 5,700 to 6,840. This should be seen as an interim measure whilst the Council fully reviews the CS which is likely to see an increased housing requirement significantly in excess of 20%.

Similar changes will also need to be made to the SA which is also predicated on the CS.