Object

Representation ID: 30136

Received: 22/03/2021

Respondent: Robbie Feather

Agent: ID Planning

Windfall

The sources of supply also include a windfall allowance of 300 dwellings per annum for years 3-18. Paragraph 3.8.27 states that based on historic windfall delivery rates and future trends the Council considers that it is reasonable to make a modest assumed contribution of 300 units. Whilst the Council consider this contribution to be modest, 300 dwellings per annum equates to 16% of the annual requirement and therefore is a significant proportion of the expected supply. No evidence is provided as to what the historic windfall rates have been or what evidence there is to support a continuation of these rates. On this basis, we object to the inclusion of 300 dwellings per annum (4,800 dwellings over the plan period) as a source of supply.

Required change

Evidence should be provided to determine the appropriateness of the windfall allowance. The quantum of windfall sites being relied on comprises a significant proportion of the annual requirement (16%) and therefore it should be robustly evidenced. The information provided at paragraph 3.8.27 does not constitute robust evidence to justify the quantum of windfalls the Council is seeking to rely on.