Support

Representation ID: 8862

Received: 29/09/2021

Respondent: Woodland Manor Hotel

Agent: Phillips Planning Services

NPPF Paragraph 69 states that Development Plans and Brownfield Registers should identify land to accommodate 10% of a Local Authorities housing requirement on small and medium sites no larger than one hectare (1ha).

However, the Small Sites Topic Paper states that this requirement can be achieved without making site allocations beyond the urban area due to completions on windfall sites. We do not agree with this assertion.

We would argue that the Council are not addressing this requirement in the way envisaged by the NPPF, i.e. through Development Plans and Brownfield Registers. The Council should not be relying upon windfall development to deliver on a national policy requirement. In order to be positively prepared the Plan needs to take a proactive approach by allocating land through the Local Plan process.

As recognised by the NPPF, “Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.” (Paragraph 69)

The Council should therefore be actively encouraging small and medium sites to come forward, whether that be by allocating site sin the Local Plan, or delegating such allocations to local communities, to be delivered by Neighbourhood Plans. They should not simply attempt to reach the minimum requirement. Housing on small and medium size sites that are delivered through windfall development should be seen as a bonus.

We appreciate that the strategy consultation is not detailed and does not identify specific sites or proposals, but it is inferred that development is likely to be allocated on larger sites. Therefore, we would contend that there is an opportunity to achieve the objective of housing delivery on small and medium sized sites by directing some growth to the villages where a greater proportion of small sites are being promoted. This will facilitate some proportionate growth in these settlements which will contribute towards their vitality, and the viability of existing services and facilities.

There is also an opportunity to achieve the requirements of housing delivery on small and medium sites in conjunction with the Council’s obligation to deliver Custom and Self-Build opportunities by making some of these allocations for self-build plots. Small sites in sustainable villages are ideal for delivering Custom and Self-Build housing plots. Many people interested in Custom and Self-Build want bespoke plots in villages rather than plots which are delivered as part of wider developments.