Object

Representation ID: 66794

Received: 26/06/2014

Respondent: Gallagher Estates

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Raises concerns over the composition of the Council's 12,600 housing requirement. Of those sites with planning permission not all will be developed, it is suggested that a 10% non implementation discount is applied. In relation to windfalls the NPPF only refers to them being included in the 5 yr. supply where there is compelling evidence that such sites have become available in the area and will continue to provide a reliable supply. There is no reference to windfalls being allowed within a local plan. If all sites are identified as part of the SHLAA there should be a limited amount of windfalls arising as part of the supply. If undertaken correctly the SHLAA should reduce uncertainty of unknown sites coming forward during the plan period. The Council's windfall paper fails to acknowledge that the number of windfall sites has been greater than plan allocations due to the existence of a policy vacuum with few allocated site remaining. The lack of a five year housing supply is likely to have encouraged sites of a windfall nature to come forward. The level of windfalls going forward is likely to reduce. In terms of the analysis of different windfall types it is unclear why sites in and on the edge of rural villages have not been assessed as part of the SHLAA process. The Council has attempted to estimate future trends for this category and added 40%. There is no justification for this. In terms of conversions and changes of use, it is accepted that development arising from this source can be unexpected and reactive to socio economic changes. There is a finite supply of such sources (such as public buildings) and it should not be assumed trends will continue. Known vacant sites should be assessed in the SHLAA. For the category relating to redevelopment/ new build sites with a capacity of 5 or more dwellings, these should all be identified within the SHLAA and accordingly if deliverable it should be categorised as an identified SHLAA site as being suitable within the plan. The inclusion of a windfall allowance is not encouraged by government policy. The correct approach is to undertake a comprehensive review of all land supply in order to get a true understanding of the land likely to come forward. The only category worthy of inclusion as windfall within the Local Plan is redevelopment/ new builds fewer than 5 dwellings. It would then total 144 dwellings over the whole plan period for windfalls.