Figure 12 (page 81) and Appendix 3 suggests that in years 10 - 15 of the Plan period (2023 - 2028) some 18% of the total housing supply in villages will come from small windfall sites (amounting to 118 dwellings). Given the considerable uncertainty of housing from this form of supply, the overall housing requirement in villages should be increased to provide a contingency against such windfall housing failing to materialise. If supply from this source were to materialise, then through annual monitoring, the release of allocated housing sites could then be held back for later release.

The range of 950 - 1,000 additional dwellings in villages (paragraph 12.13 and part (v) of the Policy) or the 975 dwelling mid-point (Appendix 3) implies a substantial reduction in the level of housing supply in rural settlements compared to the 20 year period between 1987 - 2007 when 2,300 dwellings were constructed (paragraph 12.14). This housing development has been achieved with little obvious detriment to villages or their rural settings and has been important in order to sustain village shops, public transport and community services as well as providing for housing choice and market-led affordable housing. There is insufficient justification given in the PSCS to support the claim (in paragraph 12.14) that the past rate of housing development "is an unsustainable trend", particularly in view of the high level of housing need within rural areas and the importance of rural settlements generally in contribution to overall housing supply in the District.