Re: Small Sites Allowance - Public forum - Planning Advisory Service (PAS)

Andrea thanks for that information - in terms of your Core Strategy how did you deal with sites of less than 5 units ? Did you make an any allowance for them in your calculation of your housing requirements ?

Not sure how windfalls can contribute significantly given the wording of PPS3 para 59 which states 'Allowances for windfalls should not be included in the first 10 years of land supply unless LPAs can provide evidence of genuine local circumstances that prevent speciifc sites being identified' It seems the NPPF is still some way off and may even be subject to further consultation, so i would have thought LPAs who assume relaxation of rules within PPGs/PPSs play a risky game (parallels to SE Plan/Cala Homes situation?). Although not specified in PPS3, we were always advised by the now defunct regional partnership board (SE in our case) that there is an urban/rural dimension to this as well. The advice was basically there could only be 'genuine local circumstances' for including small site windfalls within an urban borough - rural districts should not even bother trying. Not sure what has changed on this front, unless I have missed something? Where windfalls have been successfully included in a rural area, has this been restricted to small sites in years 10-15? Would be interested in any examples to the contrary.

Roger, I would suggest that small identified sites and windfall are not the same.

Joanne - that is the point! We are fully aware of the advice on making an allowance for windfalls - we are in fact not looking to make any allowance for windfalls, rather seeking other's experiences on approaches that take account of identified yet unallocated small sites in contirbuting towards the overall housing provision within the plan area, and Inspectors views on such an approach...

Michael Apologies for misunderstanding. Not aware of any examples of small identified sites being included. We kept a record of such sites during the SHLAA process (under 0.2ha or not capable of accommodating 6 dwellings), but they did not count towards our total. My concern with including them would be that they did not undergo the rigour of SHLAA analysis. Whilst we could point to them on a map, we could not demonstrate them to be 'available', 'developable' or 'deliverable'. I would be interested in the basis of any allowance/assumptions on these factors that could be made?

Michael, I am sorry but we are not far enough advanced to help you but would be interested to know how you get on. We have a significant number of small sites (in our case any site with less than 10 dwellings) identified in our SHLAA that we may want to rely on when preparing our plan and discussing the potential delivery of the overall housing figure.

We are at draft stage with our SHLAA and have identified a number of small sites which we have done a comprehensive suitabilty assessment on against 42 constraints. We have looked at past build out rates of similar sites. We grouped them into broad locations and will argue they hold some potential. The capacity we attribute to them is less than the actual delivery on these types of sites in the past over a ten year period. We have not gone as far as to test their full deliverability developability though which would invlove too much resource. They are also too small to be full SHLAA sites and too small to allocate. They are not windfalls as they are identified and have been analysed though we don't suggest any specific ones will come up. The PAS adice on SHLAA's July 2008 argues that if they can be grouped into broad locations they can provide a better understanding of the contribution smaller sites could make and could allow for a SHLAA to avoid having to identify a windfall assumption as well. Will let you know if this proves to be a sound approach.