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Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5664

Received: 07/09/2021

Respondent: Hallam Land Management

Agent: David Lock Associates

Representation Summary:

Paragraphs 3.26 – 3.28
Housing on small sites, in the context of the National Planning Policy Framework and requirement for the Council to deliver 10% of the housing requirement on small sites no larger than one hectare, is linked by the Borough Council in 3.26 to windfall housing development.

The Borough Council’s proposed windfall allowance is based on monitoring of past windfall delivery rates during 2015-2020 which found that the number of dwellings built on small sites was consistently above 10% of the annual housing requirement. Whilst this is a logical approach for planning for development on small sites, Hallam Land Management has concerns about how the trend in windfall will continue spatially across the borough.

Whilst windfall development is likely to continue, Hallam is concerned that opportunities for development in smaller settlements will become more constrained as existing opportunities on brownfield and infill sites are developed which leads to concerns on how smaller settlements can continue to accommodate modest levels of growth to support existing community facilities.

In Hallam’s view, whilst windfall will continue to contribute to housing supply, the overall amount is likely to be increasingly composed of changes of use allowed under permitted development rights and be more focused in Bedford. Increasingly limited opportunities outside the Bedford Urban Area supports a rational for allowing for planned provision, certainly in the Key Service Villages if they are to fully support the adequate provision of education, wider services and sustainable transport.

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