MOD 7.19

In insert paragraph 7.58 particular attention is given to the incidence of large windfall sites, which may increase the actual scale of housing growth over the plan. This is irrelevant as the Councils housing target is a minimum figure and any Windfall allowance should only apply to small sites. In other words potential sites should be identified in the SHLAA or updated in the Annual Monitoring Reports.

Mod 7.19: Man modification not sound. Large windfall sites should never happen. If RDC has done the correct analysis of sites available, then all potential sites should have been covered.
If a site does come up, then it should be included in the allocation for the area in which the site is situated, otherwise that area may become unsustainable.

The additional sentence, taken with the preceding text, implies that the level of development being planned for may be restricted in the future. This is inconsistent with the proposal that the housing target should be a minimum figure (proposed modification 7.6). The proposed housing figure has in any case only been limited due to the Council's belief that there may be limited capacity for development within the District. The Council's evidence shows that there is a need for more housing tom be delivered within the housing market area than has been proposed in these modifications.

The premise that a higher level of development could not be accommodated within the rural area has not been proven in the updated evidence. We understand that the 'previously unidentified' sites referred to here would not have been identified in the Council's latest SHLAA. We also understand that the proposed housing requirement figures for the villages, set out in the proposed replacement version of Figure 12 (proposed modification 12.5) are closely modelled on the suitable, achievable and deliverable sites the Council have identified in their SHLAA. Should additional sites be granted planning permission, they would also by definition be suitable, achievable and deliverable sites, and their presence alongside the SHLAA sites would indicate that there were more such sites in the rural area than the Council currently believe to be the case, and therefore than the capacity for development is also greater.

This would in turn imply that it would be possible to deliver a greater level of housing in the rural area than is currently anticipated, without unacceptable harm with regard to environmental factors. We support the Council's proposal for the new housing target to be a minimum figure (proposed modification 7.6). It is consistent with this principle that the Local Plan should anticipate that more development may come forward in the District as a whole, and we believe most probably in the rural area, through windfall sites. This development should not be restricted by any provisions within the plan, as to do so would be contrary to paragraph 47 of the NPPF, which requires local authorities to meet the full housing needs of the housing market area. The plan does not do this at present, and any means by which this may be achieved should not be discounted.

The addition takes no account of the actual effect of windfall sites be they small or large in a village setting. This provision should permit the LPA to count windfall sites against any pre-set allocation for any particular village so that the village does not have to accept its housing allocation PLUS any windfalls in addition which may be granted during the plan period.