Object

Representation ID: 6299

Received: 10/09/2021

Respondent: Messrs A Porter, H Fowler, W Salsbury Ltd

Agent: DLP Planning Limited

Our client objects to paragraph’s 3.26 – 3.28 on the basis of soundness concerns with the proposed approach (not consistent with national policy; and, not justified).
The Council’s proposed approach to enabling the development of small sites as a source of flexibility in supply and to provide diversity within the construction sector is misconceived inconsistent with national policy, ineffective and not justified. The Council is simply seeking to ignore the requirements at paragraph 69 of the NPPF2021 and undermine the government’s objectives to support inter alia SME builders and measures to address affordability.
The Council seeks to rely on evidence of past and expected future trends in windfall development in place of the requirement in national policy to identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare.
The reasoning for the approach in national policy is simple: the development plan is the most appropriate vehicle to set out positively prepared policies to support the delivery of small sites and enable small and medium developers (who often face the greatest barriers to entry in the sector) to secure implementable planning permissions more easily.