Chapter 3 - Housing Strategy Amount of Housing SP11 Respondent Responde Responden Responde Agent What is the Comment What changes do you suggest to make the document Comm Attached Subm Surname nt First t nt Name nature of legally compliant or sound? ent ID documents ission Name Organisati number this Meth on Name in this representa od document tion? . St Johns 311 Claire Mills Object It is not considered that the windfall allowance identified is Table 3 should be updated to reduce the extent of windfall 936 061 Mills Claire Email College - Savills positively prepared or justified. Table 3 expects 225 units per allowance to 200 per annum. This is considered a modest Savills Table 3.pdf annum (excluding the initial 3 years to avoid double counting reduction but a fairer reflection of the circumstances (1.5 MB) planning permissions). However, the Council's published SHLAA relating to windfall for he District in the last 10 years. (July 2018) explores historic windfall completions. For the last ten years, 2,141 windfall sites of less than 10 units have been The resulting 250 reduction in the windfall allowance delivered. Windfall completions of 10 or more units have should then be reallocated to new totalled 1,749 in the last ten years. allocations o secure certainty and confidence in Whilst the Council takes the pragmatic decision to exclude deliverability. It is suggested that a selection of small- major developments of 10 or more units from historic windfall medium allocations would best address this need, delivery, it is considered that too much reliance is placed on facilitating prompt delivery that can help immediately delivery of minor windfall schemes of less than 10 units in the address housing need and so provide a suitable balance land supply. It is evident that the emerging Local Plan between the large strategic sites and smaller modest comprises a number of minor allocations of less than 10 units, schemes. namely: Alloca Address Total St John's College own a number of additional smaller scale sites that are suitable, available and deliverable to address tion Allocated this need. These vary in capacity from providing 4 up to Ref (less than 120 homes. These sites have been submitted to Thanet Numb 10 units) District Council at various stages of the Local Plan er production but summary principles are set out below. S112 Adiacent to 8 Chapel Place, Ramsgate 6 Maior Sites (Capacitv for 10 or more Dwellinqs} Land east of Willetts Hill Monkton The site totals approximately 2.3 hectares and is S158 r/o 7-10 Marine Gardens- 5 Dwellings 6 considered to be suitable for up 50 dwellings. The Site is not subject to any landscape or S295 38, 38a and 42 8t Peters Road, Broadstairs 5 heritage designations and it is considered that high quality development will enhance the existing site and its setting. S322 Units 1-4 Monkton Place, Ramsgate 5 The site is accessed off Willetts Hill, which connects to the A253 to the north and already S467 Furniture Mart, Booth Place, Grotto Hill 9 provides access to Collars Close, which is a small cul-de-sac on the opposing side of Willetts Hill. This is in addition to existing residential properties that front onto this road. SR45 1 Thanet Road, Margate 5 The southern extent of Willetts Hill is consequently already SS43 Magnet and Southern, Newington Road, 8 benefiting from a residential character and so proposed Ramsgate development at this location would appear a natural extension to the existing settlement. - Shottendane Farm. Margate 8 There are no on site constraints that could hinder the deliverability of the site. Whilst a Scheduled Ancient Monument (remains of an Anglo-Saxon S46 Rear of 59-65 Harold Rd 9 cemetery) is located circa 210m to the north east, the site is considered sufficiently distinct and separate from this designated asset. Furthermore archaeological Total 61 investigations as part of any future planning application can ensure any potential artefacts within the site are adequately assessed and recorded . The fact that the emerging Local Plan opts to allocate spec An overhead line crosses the site but this need not affect ific minor sites indicates their expectation to progress the layout of the scheme. It is through an allocation as opposed to counting towards windfall. anticipated that the line would be undergrounded as part The fundamental issue with reliance on a significant windfall of any future development. derives from the five year housing land supply position. Thanet District Council has been subject to an out of date Local Plan, Monkton benefits from a primary school, public house and failing to have reviewed the currently adopted Plan from 2006. bus stops connecting to Minster to the east, which Furthermore, and exacerbated by this out of date plan, Thanet benefits from substantially more services including a District has not been able to demonstrate a five year housing railway station. As noted at paragraph 55 of the 2012 land supply. In such circumstances where the presumption in NPPF and paragraph 78 of the 2018 NPPF (which iteration favour is often triggered, a Council will tend to rely far more applies will be influenced by when the LPA submit the heavily on windfall sites of all sizes. It is inevitable that where Local Plan for Examination), the interrelationship between insufficient allocated sites exist, windfall sites will dominate settlements should be acknowledged and the opportunity supply. Whilst this may appear to indicate that a District has for development in one village to help support services in historically benefited from significant windfall, it is contested a village nearby. that this should be given such weight hen calculating housing need and the assumptions that windfall will contribute to Land to the South of Monkton Street, Monkton supply. The statistics are clearly flawed . In a scenario where a Development of the land to the south of Monkton Street Local Plan is being prepared and adopted, the case is made provides the opportunity for a high quality residential that housing supply should plan for the scenario where a development on a small, well contained land parcel five year supply of deliverable sites can and will remain providing a natural extension to the settlement. The site effective. In such circumstances, the presumption in favour totals circa. 1.2ha and is considered suitable to would not be triggered and the proportion of windfall sites accommodate up to 20 dwellings. This is slightly less than would inevitably reduce. typically expected for a 1.2ha site due to allowance made It is appreciated that the Council has deducted major sites of 10 for the site shape. For instance, it is envisaged that or more from the windfall allowance. However, the Council has dwellings would only be located on one side of the access made no acknowledgement of the fact that they do road connecting onto Monkton Street until the site widens nevertheless allocate sites of less than 10 dwellings. One must to the south. The site capacity also makes allowance for consequently consider this and the fact that windfall sites are the retention of the copse to the south eastern corner of not necessarily a never-ending source, particularly if the Council the site where pond (believed seasonal) is also located. assumes the majority to relate to brownfield land as claimed. Despite the proximity of field drains, it is reiterated that It is not argued that a drastic reduction in windfall allowance is the site falls within flood zone 1, the zone 1, the zone to required. Instead, it is considered that the calculation of which development should be directed. windfall is flawed. Whilst it is agreed as appropriate for the Council to not take into account the 3 most recent years of The site is within the sole ownership of our client and is windfall in the supply totals to avoid double counting with considered suitable, available and deliverable within the planning permissions, the same should not apply when simply next 1-5 years. Furthermore, if one excludes the south calculating the windfall average itself. It one uses the mean eastern copse from the site area, it is evident that the site average for windfall completions from 2008/09 up to the latest would be no more than 1ha. In the scenario where the evidence , which is 2017/18, it is clear that the evidence submission timings of the emerging Local Plan mean that indicates an average of 214 windfall units per annum for the 2018 NPPF applies, this site could consequently readily schemes of 10 or less. The table is summarised below: address the need for 10% of the housing requirement to Year Windfall Sites <10 be met through sites of 1ha or less. 2008-09 367 The site is well contained by its surrounding built and .... WORD LIMIT REACHED - PLEASE REFER TO ATTACHMENT 2009-10 182 FOR REMAINDER OF REPRESENTATION - SITES: LAND WEST OF WILLIETTS HILL - MONKTON 2010-11 496 LAND TO THE NORTH OF THE LENGTH - ST NICHOLAS AT WADE LAND AT CRUMPS FARM - ST NICHOLAS AT WADE 2011-12 214 LAND SOUTH OF MARGATE HILL - ACOL LAND TO THE WEST OF SHUART LANE 2012-13 76 ST NICHOLAS AT WADE, LAND OFF SUN LANE, ST NICHOLAS AT WADE 2013-14 123 2014-15 120 2015-16 151 2016-17 183 2017-18 229 Average 214 Total (per annum) In light of this and the fact that on the adoption of a Local Plan the extent of windfall schemes will likely reduce dramatically, it is considered more proportionate for the housing land supply in Table3 to assume 200 windfall dwellings per annum.