Object

Representation ID: 9064

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

7.1. The NPPF requires local planning authorities, through their local plans, to accommodate at least 10% of their housing requirement on sites no larger than one hectare unless there are strong reasons why this 10% target cannot be achieved. The NPPF states:
“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. To promote the development of a good mix of sites local planning authorities should:
a) 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; unless it can be shown, through the preparation of relevant plan policies, that there are strong reasons why this 10% target cannot be achieved;”
7.2. BBC states that It will not comply with the NPPF regarding its requirement for identifying small sites as it states it will deliver this through windfall development:
“the Local Plan 2040 will not include allocation policies for small sites simply to satisfy this specific requirement of government policy, as we expect sufficient small sites to continue to be delivered as a result of windfall development. Small sites may however be allocated in accordance with development strategy, once it is finalised.”
7.3. BBC’s Small Sites Topic Paper includes an estimate of their 10% requirement for small sites which estimates 2,550 are required to 2040. It then provides a summary of supply from the following sources in an attempt to demonstrate that it has enough small sites to meet the Government’s requirement.
• Qualifying commitments from monitoring
• Likely supply from Neighbourhood Plans
• Likely supply from windfall
• Potential supply from urban sites in Local Plan 2040

INCLUDES FIGURE 7.1: TABLE FROM SMALL SITES TOPIC PAPER

7.4. BBC provides no background information on any of these assumptions so it is impossible for the reader to verify or not the Council’s assumptions. We request that BBC provides this information and that it is made public as soon as possible
7.5. BBC misinterprets the NPPF which does support the delivery of windfall housing sites in existing settlements through local policies and decisions however this is in addition to the NPPF’s requirement to identify small sites.
7.6. We therefore object to BBC’s proposed approach to small sites as these can form an important component of land supply in sustainable locations. BBC should undertake a small sites study in order to identify at least 10% of its housing requirement on small sites allocations.