3.27

Object

Representation ID: 3559

Received: 11/08/2021

Respondent: Brown & Co Barfords

Paragraph 3.27, page 25 sets out at 31 March 2020, 24.1% of housing supply was on small sites which
notes the importance of small sites. Paragraph 3.28 sets out the Local Plan to 2040 will not allocate small
sites. However, paragraph 68 of the NPPF 2021 sets out 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 identify,
through the development plan land to accommodate at least 10% of their housing requirement on sites no
larger than on hectare and therefore there is a requirement to allocate small sites with windfall sites in
addition.
The Local Plan should provide a range of housing sites, both small and large scale to enable flexibility and
competition in the market. Therefore, small sites should be allocated as part of the Local Plan to 2040 such
as the sites at Pertenhall as without small sites the Plan would not be consistent with national policy and
therefore cannot be deemed sound as set out in paragraph 35 of the NPPF 2021.

Object

Representation ID: 6300

Received: 10/09/2021

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

Agent: DLP Planning Limited

The Council’s own evidence in the Small Sites Topic Paper demonstrates a year-on-year fall in trends in the completion of small windfall sites against the Local Plan 2030 requirement of 970dpa. This is illustrative of issues affecting the sector. The Council must also be mindful of the fact that more recent policies in the development plan provide a further barrier to bringing forward appropriate proposals on unidentified sites.
The evidence from past trends fails to support the Council’s contention that windfall supply will provide for 10% of the higher requirement based on minimum annual local housing need for the period 2020 to 2040. The Council relies on expected future trends but the justification for its proposed approach fails for the following reasons:
• The Council’s reference to extant commitments takes no account of any potential lapse rate or double-counting with assumptions of future supply
• Expected trends take no account of changes to Permitted Development Rights (including restrictions upon office-to-residential conversions and a reduction in the number of potentially suitable sites)
• Extant small-site commitments take no account of those that are effectively ‘one-off’ schemes that would not be accessible to the SME sector (e.g., backland plots or subdivision)
• The likely supply from Neighbourhood Plans, which is a tiny proportion of the 2,260 dwellings required from this source and illustrative of these Plans often focusing development on a limited number of challenging sites, is dwarfed by the resulting restrictions on additional growth.
There are some positive aspects to the Council’s evidence base to support growth on available/deliverable small sites, such as the 136 units’ capacity identified in urban areas. It is presently unclear whether our clients’ site forms part of this total as the Council has not released details of any potential site allocation options as part of this consultation. These representations demonstrate that the former Peacock’s Auction site would satisfy the criteria for supporting development on small sites as set out in national policy and at a location that is suitable, available and achievable.
In reality, we consider that this total could be increased in order to achieve the Council’s Preferred Options to provide for a further 1,500 units within the urban area. It will be therefore necessary to maximise the potential contribution from small sites.
The Council’s total of 1,500 is over-and-above extant development plan allocations within the Town Centre that are and will remain significantly constrained. Failure to diversify urban supply without support through the development plan will result in this component of the spatial strategy being unsound.