Main Modfication 4 Chapter 4: The Development Strategy - amend paragraph 4.23 and replace with amended paragraph 4.28

We object to the inclusion of windfall allowance of 35 dwellings per year over a twelve-year period, which is contrary to the advice of the NPPF.

Paragraph 48 of the NPPF states that '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. It does NOT state that local planning authorities may make an allowance for windfalls throughout the whole of the plan period.

We believe that windfall allowance should be capped to 35 units a year for 5 years. 175 units in total.

In respect of the tests of soundness, an over reliance on windfall sites renders the plan unjustified because it is not the most appropriate strategy when considered against the reasonable alternatives. i.e. choosing speculative 'windfall' housing over the identification of 'deliverable' housing at Breadsell Lane.

The test of being 'effective' also requires the plan to be deliverable over its period. We consider that 175 units would be deliverable over the plan period, even if they didn't come forward strictly in the first five years. However, a figure of 420 units provide too much burden on the 'unknown' and too wider degree of uncertainty to be able to be deemed a positively prepared plan.

See attached.