Object

Representation ID: 22159

Received: 06/10/2021

Respondent: Marlie Civils

Agent: RCA Regeneration Ltd

At 7,657 (Table 3), we consider the windfall allowance to be high - it represents around 16% of the total housing target for the plan period, which is a considerably proportion. Given the requirements of the NPPF, we consider the plan is at risk of not being 'positively prepared' given this (we feel) overreliance on unallocated housing in the emerging plan. Paragraph 71 of the NPPF sets this out clearly: 'Where an allowance is to be made for windfall sites as part of anticipated supply, there should be compelling evidence that they will provide a reliable source ofsupply. Any allowance should be realistic having regard to the strategic housing land availability assessment, historic windfall delivery rates and expected future trends. Plans should consider the case for setting out policies to resist inappropriate development ofresidential gardens, for example where development would cause harm to the local area.'