Comment

Representation ID: 1716

Received: 30/01/2015

Respondent: Cogent Land LLP (Cogent)

We have noted that a substantial proportion of future dwellings in the Borough are intended to be delivered through windfall development. The NPPF (Paragraph 48) clearly sets out that Councils can include windfall sites in their five year land supply figures, but only where there is compelling evidence -
"Local planning authorities may make an allowance for windfall sites in the five-year supply if they have compelling evidence that such sites have consistently become available in the local area and will continue to provide a reliable source of supply. Any allowance should be realistic having regard to the Strategic Housing Land Availability Assessment, historic windfall delivery rates and expected future trends, and should not include residential gardens."
We have therefore looked at historic evidence (see table below), which the Council has produced. This indicates the reliance on windfall development to deliver a significant proportion of the Borough's housing need.
The Council has identified a strong and consistent historic delivery of windfall sites. However Paragraph 48 not only requires Authorities to show compelling evidence of delivery, but also that Windfall sites will continue to provide a reliable source of supply.