Breaches re "Soundness" include:
The evidence is flawed since the Hambro Nursery and Clovelly Works site has been disregarded without due process or logic.
Brownfields must always be preferred ahead of green belt.
Breaches re "Legal Compliance" :
It clearly does not comply with the Statement of Community Involvement, as the Parish Council has proposed alternatives and these have not been actively considered. This is not a NIMBY proposal, brown field sites have been identified within Rawreth (Hambro Nursery and Clovelly Works).
Revised wording : Clovelly Works and Hambro Nursery will be included as substitute locations as the combined site provides a credible alternative within the community with good access to roads and services. This would also 'spread the load' and reduce the impact of such a large scale 'one site' development.

The interests of the pragmatic and willing local residents, views of the Parish and District councillors and serving MP should be taken into consideration. The open-minded approach of the local residents (in accepting a degree of change) has been betrayed by the Ditsrict Council's inflexibility in forming these adopted proposals.

Breaches falling under the "Soundness" umbrella include:

Despite logical, lower impact proposals for Hambro Nursery and Clovelly Works to be included the District Council have proceeded with the neatest proposal from a developers viewpoint. therefore it does not have a robust and credible evidence base, nor does it provide the most appropriate strategy when considered against reasonable alternatives.

It is not consistent with national policy since brownfields are always preferred ahead of green belt.

Breaches under the "Legal Compliance" umbrella include:

It clearly does not comply with the Statement of Community Involvement, as the Parish Council has proposed alternatives and these have not been actively considered. This is not a NIMBY proposal, brown field sites have been identified within Rawreth (Hambro Nursery and Clovelly Works).
Does the document conform generally to the Regional Spatial Strategy and national policy?