Support

Representation ID: 8404

Received: 27/09/2021

Respondent: WSP

Agent: WSP

HOUSING DEVELOPMENT ON SMALL SITES
The Draft Plan correctly recognises the importance of delivering development on small sites and notes the NPPF requirement for 10% of housing delivery coming forward on small sites (per Paragraph 69 of the NPPF.
This is positive and supported, as it will increase the diversity of sites that are developed across the Borough and recognises that larger sites are often difficult to develop and deliver houses much slower than smaller sites.
While it is positive that smaller sites are supported by the plan, it not justified to simply use windfall sites to meet the quota outlined in NPPF Paragraph 69. This is as the nature of windfall sites is uncertain and Paragraph 69 explicitly states that development plans should identify small sites to accommodate the 10% target and as such the current policy approach is not in accordance with the NPPF.
The Draft Plan should be amended to allow for smaller sites to be allocated and enable it to be considered sound in relation to Paragraphs 69 of the NPPF. This is due to Paragraph 35, which outlines that plans need to be consistent with national policy and justified if they are to be considered sound.