Object

Representation ID: 4354

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Table 8 includes an allowance of 600 windfall dwellings but doesn't explain how this has been derived. The Council's Five Year Supply document (2020-2021) indicates that there has consistently been a windfall supply in excess of 100 dwellings per annum. No explanation is given for the assumption of only 30 dpa when there have been over 100 windfalls in every year both before and during the current Local Plan period. Tables later in the document relate to 2021 and 2022 and show that windfalls are still a significant contributor to housing provision. Appendicies containing large and small sites later in the document show that the majority of current five year supply is from windfalls. On the basis of both 'Historic' and 'Current' data the windfall allowance is unjustifiably low, creating unnecessary Green Belt/greenfield loss.