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Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6692

Received: 14/09/2021

Representation Summary:

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 is 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 be actively encouraging small and medium sites to come forward, whether that be by allocating sites in the Local Plan, or delegating such allocations to local communities, to be delivered by Neighbourhood Plans. (We have made separate representations on the matter of NP’s in response to paragraph 1.48 of the consultation paper).

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.

The Plan going forward needs to plan for a significant increase in housing numbers up to 2040, and small and medium sites can make a meaningful contribution towards this. The Council should therefore make provision for this in the Local Plan.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7537

Received: 21/09/2021

Representation Summary:

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 sites in 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.

The Plan going forward needs to plan for a significant increase in housing numbers up to 2040, and small and medium sites can make a meaningful contribution towards this. The Council should therefore make provision for this in the Local Plan, and we would highlight that our client’s promoted option for a site of 20 dwellings at Top Farm, Wyboston, could make a positive contribution towards this objective.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8097

Received: 02/09/2021

Representation Summary:

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.

The Plan going forward needs to plan for a significant increase in housing numbers up to 2040, and small and medium sites can make a meaningful contribution towards this. The Council should therefore make provision for this in the Local Plan.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8862

Received: 29/09/2021

Representation Summary:

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.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 9064

Received: 12/11/2021

Representation Summary:

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.

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