2. Housing Land Supply 2016-2036
2.1. This section details the components of supply of housing land which will contribute towards the Local Plan housing requirement of at least 10,420 (net) dwellings.
Housing Delivery in the Plan Period to Date
2.2. Table 2 shows that 1,705 dwellings have been completed so far in the Plan period 2016- 2036 for the Local Plan which is an average of around 341 dwellings per year, compared with the annual target of 300 dwellings (1,500 dwellings for the period 2016-2021).
Year | Total Completions |
|---|---|
2016/17 | 350 |
2017/18 | 266 |
2018/19 | 359 |
2019/20 | 308 |
2020/21 | 422 |
Total | 1,705 |
Large Permissions (Sites of 10 or more Dwellings)
2.3. The following sites with planning permission totalling 356 dwellings have been excluded from the overall housing supply for the Local Plan period because there is not currently a realistic prospect of them delivering homes within the Plan period:
- TOT3 Land at Hanger Farm, Totton (Permissioned: 07/89872 Detailed, 05/83625 Detailed - 330 dwellings): Land at Hanger Farm, Totton (TOT3) is a greenfield site with highway access points in place and there are no onerous infrastructure requirements. This site has longstanding permissions for 330 dwellings which remain extant by virtue of Lawful Development Certificates issued in 2007 and 2008. In the last published housing trajectory 270 dwellings from this site were included in the latter years of the Plan period. However, there has been no activity on this site for well over a decade. The developer, Stanborough Developments, has consistently and continually delayed the build-out and delivery of the site and most recently has stated (in June 2021) that they cannot access the necessary labour and raw materials to build-out the site and have no delivery programme to deliver the site. On the basis of the longstanding history of this site being stalled and the written communication from the developer, it is not considered that there is reasonable prospect of this site delivering in full the dwellings previously envisaged within the Plan period
- Manor Farm Building, Hanger Farm), Totton (Permissioned: 03/78798 Outline, 05/85757 Reserved Matters - 13 dwellings): This site adjoins Hanger Farm and is owned by the same developer, Stanborough Developments. This site has longstanding permissions for a net gain of 13 dwellings which remain extant by virtue of correspondence to the developer issued in 2007. However, there has been no activity on this site for well over a decade. The developer has recently stated (in June 2021) that they cannot access the necessary labour and raw materials to build-out the site and have no delivery programme to deliver the site. On the basis of the longstanding history of this site being stalled and the written communication from the developer, it is not considered that there is reasonable prospect of this site delivering in full the dwellings previously envisaged within the Plan period
- 1-20 Marsh Parade, Hythe (01/73799 - 7 dwellings remaining): This site has been excluded from the housing supply figures since 2018. The site is partially implemented. However, no flats have been completed or under construction since 2009 and the remaining 7 flats are therefore very unlikely to be delivered
- LYM4 Land at 142-144 Southampton Road, Lymington (10/96153 - 6 dwellings): This site has been excluded from the housing supply figures since 2018. The southern third of the allocation has been implemented delivering 4 dwellings. The remaining undeveloped portion of this site has an extant permission for 6 dwellings for which foundation trenches have been dug but no further work has happened for several years. It is currently considered unlikely that these 6 dwellings will be delivered
2.4. Table 3 below sets out existing large site permissions in the Plan Area and the capacity anticipated to be delivered over the remainder of the Local Plan period. Most of these sites are currently under construction and for those sites the number of dwellings remaining to be built on the site within the rest of the Local Plan period are noted.
Table 3: Housing capacity from existing large permissions
Allocation / Permission Reference | Site Name | Number of Dwellings remaining/expe cted to be completed in Plan Period | Comments |
|---|---|---|---|
17/11204 | Hythe and Dibden War Memorial Hospital, Hythe | 21 | Hybrid consent for new community hospital and 21 dwellings with the new community hospital having full planning permission and the residential development having outline planning permission. The new hospital is under construction and anticipated to be completed in autumn 2022. New Forest District Council has agreed a deal to purchase the part of the site with outline planning permission for 21 dwellings and will be progressing towards submitting a full planning application for the site |
20/10481 | Site of The Rise and Three Neighbouring Properties, Stanford Hill, Lymington | 40 | Under construction. Site expected to be complete in 2023/24 |
MoS1 (Permissioned: 17/10606) | Land north of School Lane, Milford on Sea | 3 | Mostly complete with only three dwellings remaining to be built. Site expected to be complete in 2021/22 |
19/11056 | Fernmount House and Centre, Forest Pines, New Milton | 49 | Pre-commencement conditions being discharged |
FORD1 (Permissioned: 17/10150) | Land east of Whitsbury Road, Fordingbridge | 28 | Mostly complete with 28 dwellings remaining to be built. Site expected to be complete in 2021/22 |
SAND1 (Permissioned: 19/11080, 19/11083) | Land west of Scout Centre, Station Road, Sandleheath | 14 | Under construction. Site expected to be complete in 2021/22 |
| Total Plan | 155 |
Permissioned Sites for Use Class C2 Care Homes
2.5. Planning Practice Guidance for specialist housing for older people was updated in 2019 and indicates that plan-making authorities may count provision for older people in Class C2 against their housing requirement. To establish the amount of accommodation released in the housing market, the guidance indicates that authorities should base calculations on the average number of adults living in households using the published Census data.
2.6. The published census confirms that that there is an average of 1.8 adults living in households in New Forest District. A ratio of 1.8 has therefore been applied to Class C2 care home accommodation. The table below sets out the two sites within the Plan Area that have planning permission for care home accommodation. This totals 64 bedrooms. Applying the established ratio of 1.8 to this equates to 35 dwellings released on the housing market. In accordance with the Planning Practice Guidance, 35 dwellings are therefore added to the supply.
Table 4: Sites with planning permission for care homes
Permission Reference | Site Name | Number of bedrooms | Current Status |
|---|---|---|---|
20/10656 | Barberry House, Wildground Lane, Hythe | 4 | Detailed planning permission for a 4-bedroom care home |
17/11358 | Land west of Crow Lane, Ringwood | 60 | Detailed planning permission for 60- bedroom care home |
Total Plan Area | 64 bedrooms |
| |
Average number of adults per household | 1.8 |
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Contribution from C2 care homes to housing supply | 35 dwellings |
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Small Permissions (Sites of less than 10 Dwellings)
2.7. Existing unimplemented planning permissions for sites with a net gain of less than 10 dwellings also contribute to the supply for the Plan period. Schemes for permission that fall below this threshold are considered collectively. Rather than site by site monitoring of phasing for these schemes, we have applied a 10% discount to the outstanding net gain in dwellings to take account of the potential level of uncertainty regarding the exact number of permissions that will be implemented. This approach is considered to provide the appropriate level of confidence and degree of flexibility in the figures and was supported by the Inspectors at the Local Plan examination. The supply and phasing expected from permissioned small sites is explained in Table 5 below.
Table 5: Housing capacity from small site commitments
| Capacity | Projected Housing Completions | |||
|---|---|---|---|---|---|
|
| 2021/22 | 2022/23 | 2023/24 | 2024/25 |
Total Plan Area | 270 | 77 | 77 | 77 | 39 |
Non-permissioned adopted Local Plan Part 2 (2014) Allocations
2.8. There are a number of remaining Local Plan Part 2 (2014) allocations that remain nonpermissioned. Following a review of their continued suitability and deliverability the following sites totalling 609 dwellings have been excluded from the overall housing supply for the Local Plan period as there is not currently a realistic prospect of them delivering homes within the Plan period:
- TOT6 Land at Jackie Wigg Gardens, east of Brokenford Lane, Totton (10 dwellings): The site has numerous landowners. The site is still in business (car repair/light industrial) use. There is not currently a reasonable prospect that the site will become available or come forward before 2036
- TOT9 Bus Depot, Salisbury Road, Totton (15 dwellings): The site is still in bus depot use and no information has yet been received from the landowner as to their intentions or whether site is still available. There is not currently a reasonable prospect that the site will become available or come forward before 2036
- TOT11 Land at Eling Wharf, Totton (400 dwellings): The site is owned by ABP, will be needed for their port-related needs at least in the short/medium term and whether it becomes available could be at least in part contingent on what happens regarding Dibden Bay. It is not yet known whether the site will become available and come forward before 2036. However, this situation may change over the Plan period, and it is understood that the landowner still has longer term aspirations to redevelop the site for residential-led development
- BLA1 Land adjacent to Blackfield Primary School, Blackfield (30 dwellings): No progress made at all and no information on site availability. There is not currently any prospect that the site will become available or come forward before 2036 • LYM5 Fox Pond Dairy Depot and Garage, Milford Road, Lymington (14 dwellings): The site has two landowners. The garage/showroom on the southern part of the site still in operation. A recent full planning application (19/11555) sought to develop the garage/showroom part of the site for A1/A5 use which was refused in April 2020 and dismissed at appeal. The owner of the dairy in the northern section of the site has confirmed that they have no plans to bring their site forward for residential development in the foreseeable future. There is not currently any prospect that the site will be delivered for the use allocated in the Plan period
- NMT4-NMT6 Land at Caird Avenue, New Milton (130 dwellings): This site has been excluded from the housing supply figures since 2019. The western portion of the site (NMT4/NMT5) is allocated in the 'made' New Milton Neighbourhood Plan for commercial development only as residential development is no longer considered possible on the site. The eastern part of the site (NMT6) is in use for gravel processing / extraction and will not be available within the Local Plan period
- NMT8 Ashley Cross Garage, Ashley Lane, New Milton (10 dwellings): The site has numerous landowners. The site is still in business (garage/car showroom) use. There is not currently a reasonable prospect that the site will become available or come forward before 2036
2.9. The other remaining existing non-permissioned adopted Local Plan allocations listed in Table 6 below remain suitable and available for housing development with a reasonable prospect of them from coming forward within the Local Plan period 2016-2036. It is therefore justifiable for them to form part of the overall housing supply.
Table 6: Housing capacity from non-permissioned adopted Local Plan Part 2 (2014) Allocations
Allocation Reference | Site Name | Capacity in Plan Period | Comments on Progress |
|---|---|---|---|
TOT1 | Land at Durley Farm, Totton | 80 | Taylor Wimpey undertook pre- application discussions in the second half of 2019 and early 2020. Taylor Wimpey has an option on the area of the site owned by Barker Mill Estates (the majority of the allocation). Taylor Wimpey has confirmed it is refining the development proposals and working on bringing forward an outline planning application and anticipates submitting the outline planning application in summer 2022. Based on this, there is still clear current interest in bringing forward the site and a reasonable prospect of full delivery within the Plan period |
MAR1 | Land between Cracknore Hard Lane and Normandy Way, Marchwood | 12 | The site is owned by the Ministry of Defence (MoD). The MoD has confirmed that whilst there are no plans to bring the site forward in the short-term, the site is anticipated to be available for residential development within 6-10 years and could reasonably be brought forward in that timeframe. There is justifiable evidence to continue to include this site within the overall housing supply for the Plan period |
MAR3 | Land south of Hythe Road, Marchwood | 15 | The site is available now and is currently being marketed for development. There is justifiable evidence to continue to include this site within the overall housing supply for the Plan period |
MAR4 | Land off Mulberry Road, Marchwood | 15 | The site is owned by the Ministry of Defence (MoD). The MoD has confirmed that whilst there are no plans to bring the site forward in the short-term, the site is anticipated to be available for residential development within 6-10 years and could reasonably be brought forward in that timeframe. There is justifiable evidence to continue to include this site within the overall housing supply for the Plan period |
HYD2 | Land at Cabot Drive, Hythe | 10 | Hampshire County Council is in the process of the selling the site to New Forest District Council who will bring the site forward for residential development |
NMT2 | Land west of Moore Close, New Milton | 15 | The site is owned by New Forest District Council and the Council is bringing forward the site. The site has resolution to grant full planning permission for 16 dwellings (21/10932) and the full planning permission is expected to be issued in February 2022 |
NMT3 | Land off Park Road, Ashley, New Milton | 20 | The landowners have confirmed that they still intend to bring the site forward and that they expect the site to be available for development within 3-5 years. They envisage realistically submitting pre-application request and planning application within 3 years. Based on this, there is still clear current interest in bringing forward the site and a reasonable prospect of delivery within the Plan period |
ASH1 | Land adjoining Jubilee Crescent, Ashford | 10 | An outline planning application for 7 dwellings (21/11490) was submitted in November 2021 |
Total Plan Area | 177 |
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Local Plan 2016-2036 Part 1 Strategic Site Allocations
2.10. The Local Plan 2016-2036 Part 1: Planning Strategy allocates 18 new strategic sites which in total will contribute at least 5,995 homes during the Plan period. The minimum housing capacities in the Plan period of each of the strategic site allocations and the progress made so far on bringing them forward is set out in Table 7 below.
2.11. The vast majority of the strategic site allocations are either now in pre-application discussions or at planning application stage and a number have housebuilders in place to deliver them. Most of the planning applications submitted for the strategic sites thus far are for a higher number of dwellings than the minimum site figures set out in the Local Plan. It is likely therefore that at least some of the strategic site allocations will achieve planning permission for a higher number of dwellings than that set out in the minimum capacity estimates.
Table 7: Minimum housing capacity from Local Plan 2016-2036 Part 1 strategic site allocations
Site Name | Minimum Capacity in Plan Period | Comments on Progress |
|---|---|---|
SS1 Land north of Totton, Totton | 1,000 | Land north of Salisbury Road - Housebuilder: Bloor Homes Resolution to grant outline planning permission subject to s.106 Agreement - 20/10997 (up to 280 dwellings) (Submitted September 2020, Resolution to approve given by Planning Committee July 2021). An Environmental Impact Assessment (EIA) Screening Request (Screening Opinion) (20/10464) concluded that proposed development is not an EIA development Land west of Hill Street - Housebuilder: Bargate HomesPre-application discussions are advanced. A full planning application is expected. An Environmental Impact Assessment (EIA) Screening Request (Screening Opinion) (21/10379) concluded that proposed development is not an EIA development Land west of Pauletts Lane No progress made Land north of Loperwood, west of Pauletts Lane - Housebuilder: Pennyfarthing Homes Initial pre-application advice has taken place Land east of Pauletts Lane - Promoter: L Reeves and Merlion Capital Pre-application discussions ongoing in advance of submission of an outline planning application. An Environmental Impact Assessment (EIA) Screening Request (Screening Opinion) (21/10564) has been given Land at Sharves Hill, east of Pauletts Lane - Housebuilder: Pennyfarthing Homes Initial pre-application advice has taken place Land at Loperwood Lane - Housebuilder: Aster Communities Site is now under construction. Reserved Matters permission granted in October 2020 - 19/10703 (80 dwellings). Outline permission (15/11797) for up to 80 dwellings granted October 2017 |
SS2 Land south of Bury Road, Marchwood | 700 | Promoter: Trustees of the Barker Mill EstatePhased to commence from 2026/27 after completion of mineral extraction and land remediation |
SS3 Land at Cork's Farm, Marchwood | 150 | Promoter: Oceanic Galaxy Ltd Hybrid planning application being determined - 21/11293 (Up to 150 dwellings) (Submitted September 2021). An Environmental Impact Assessment (EIA) Screening Opinion (20/10434) concluded that proposed development is not an EIA development |
SS4 Former Fawley Power Station, Fawley | 1,380 | Developer: Fawley Waterside Resolution to grant outline planning permission subject to s.106 Agreement (19/10581 - 1380 dwellings and 95,300sqm of commercial, civic and employment floorspace) (Submitted May 2021, Resolution to approve given by Planning Committee July 2021). An Environmental Impact Assessment (EIA) Scoping Opinion (17/11559) has been given. Applications (19/10131 and 19/10138) for the demolition of the power station buildings and clearance and remediation of the site were approved in May 2019 |
SS5 Land at Milford Road, Lymington | 185 | Land north of Milford Road - Housebuilder: Colten Developments Technical studies and assessments are in progress Land south of Milford Road (Majority) - Housebuilder: Bargate Homes Outline planning application being determined - 20/11192 (up to 110 dwellings) (Submitted October 2020). An Environmental Impact Assessment (EIA) Screening Request (Screening Opinion) (20/10847) concluded that proposed development is not an EIA development Land south of Milford Road (Minority) - Developer: Efford Construction Ltd 3.4ha parcel south of the Bargate Homes site. Initial pre-application discussions have taken place |
SS6 Land east of Lower | 100 | Promoter: Cicero Estates (controls majority of the allocation) Pre-application discussions ongoing in advance of submission of an outline planning application. An Environmental Impact
2ha parcel in the northwest part of the allocation. Initial preapplication advice has taken place |
SS7 Land north of Manor Road, Milford on Sea | 110 | Housebuilder: Pennyfarthing Homes An Environmental Impact Assessment (EIA) Screening Request (Screening Opinion) (21/11238) concluded that proposed development is not an EIA development. Pre-application discussions have started |
SS8 Land at Hordle Lane, Hordle | 160 | Parcels adjoining north and south Hordle Lane - Housebuilder: Bargate Homes An Environmental Impact Assessment (EIA) Screening Request (Screening Opinion) (21/11511) has been submitted (November 2021). Site masterplanning and technical studies progressing. Pre-application advice has started The Coal Yard - Promoter: Amirez Ltd Full planning permission granted in August 2020 - 19/10007 (10 dwellings) Land west of Vicarage Lane - Housebuilder: Pennyfarthing Homes Initial pre-application advice has taken place |
SS9 Land east of Everton Road, Hordle | 100 | Housebuilder: Bargate Homes Full planning application being determined - 21/11731 (103 dwellings) (Submitted December 2021). An Environmental Impact Assessment (EIA) Screening Request (Screening Opinion) (21/10329) concluded that proposed development is not an EIA development |
SS10 Land east of Brockhills Lane | 130 | Housebuilder: Pennyfarthing Homes Full planning application being determined - 21/11179 (169 dwellings) (Submitted August 2021). An Environmental Impact Assessment (EIA) Screening Request (Screening Opinion) (20/10320) concluded that proposed development is not an EIA development |
SS11 Land south of Gore Road, New Milton | 160 | Promoter: Hurst Castle and Lock Investments (Gore) LLPPre-application discussions ongoing and an Outline planning application for the whole site is anticipated in spring 2022. An Environmental Impact Assessment (EIA) Screening Request (Screening Opinion) (20/10692) concluded that proposed development is not an EIA development |
SS12 Land south of Derritt Lane, Bransgore | 100 | Housebuilder: Wyatt Homes Full planning application being determined - 21/11097 (100 dwellings) (Submitted July 2021). Screening Request (Screening Opinion) (20/11271) concluded that proposed development is not an EIA development |
SS13 Land at Moortown Lane, Ringwood | 480 | Housebuilder: Crest Nicholson (controls majority of the allocation) Hybrid planning application being determined - 21/11723 (Outline planning application for up to 323 dwellings, full planning application for 168 dwellings (Submitted December 2021). An Environmental Impact Assessment (EIA) Screening Request (Screening Opinion) (21/10339) has been given which concluded that an EIA will be required |
SS14 Land north of Hightown Road, Ringwood | 270 | Housebuilder: Taylor Wimpey Outline planning application being determined - 21/10042 (up to 400 dwellings and 3ha of employment land) (Submitted January 2021). An Environmental Impact Assessment (EIA) Scoping Opinion (19/10735) has been given |
SS15 Land at Snails Lane, Ringwood | 100 | Promoter: Gladman Developments Outline planning application refused by Committee in June 2021 - 18/11606 (up to 143 dwellings) (Submitted December 2018). A fresh Outline planning application is expected in early 2022. An Environmental Impact Assessment (EIA) Screening Request (Screening Opinion) (18/11405) has been given. EIA required. An Environmental Impact Assessment (EIA) Scoping Opinion (18/11627) has been given |
SS16 Land north of Station Road, Ashford | 140 | Promoter: Infinite Homes Outline planning application (20/10522) for 240 dwelling was originally submitted in May 2020. Following correspondence with the Case Officer, the applicant has been working on revised proposals which include a reduction in the number of dwellings proposed to under 200 and amendments to the access arrangements. These revised proposals are anticipated to be submitted during the first quarter of 2022. An Environmental Impact Assessment (EIA) Screening Request (Screening Opinion) (19/10006) concluded that proposed development is not an EIA development |
SS17 Land at Whitsbury Road, Fordingbridge | 330 | Land at Tinkers Cross Farm - Housebuilder: Pennyfarthing Homes Full planning application being determined - 20/11469 (64 dwellings) (Submitted December 2020). An updated Environmental Impact Assessment (EIA) Screening Request (Screening Opinion) (21/10307) concluded that proposed development is not an EIA development Land west of Sweatfords Water - Housebuilder: Pennyfarthing Homes Outline planning application being determined - 21/10052 (around 400 dwellings) (Submitted January 2021). An Environmental Impact Assessment (EIA) Scoping Opinion (20/10351) has been given |
SS18 Land at Burgate, Fordingbridge | 400 | Land west of Burgate, Salisbury Road - Housebuilder: Pennyfarthing Homes Hybrid planning application being determined - 21/11237 (Outline planning application for residential development (around 405 dwellings), together with a community hub (to comprise a mix of some or all of; local food retail, local non- food retail, community use and business use). Full planning application for the first phase of development comprising 111 dwellings) (Submitted September 2021)). An Environmental Impact Assessment (EIA) Scoping Opinion (20/10352) has been given Land at Burgate Acres - Housebuilder: Metis HomesResolution to grant full planning permission subject to s.106 Agreement - 20/10228 (63 dwellings) (Submitted February 2020). An Environmental Impact Assessment (EIA) Screening Request (Screening Opinion) (19/10993) has been given. EIA required. An Environmental Impact Assessment (EIA) Scoping Opinion (19/11560) has been given Land at Middle Burgate House - Developer: Mr B Currie Pre-application discussions ongoing |
Total Plan Area | 5,995 |
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New Milton Neighbourhood Plan Sites
2.12. Policy STR5 of the adopted Local Plan 2016-2036 Part 1: Planning Strategy sets out a target for the New Milton Neighbourhood Plan to identify additional sites sufficient to deliver around 200 additional dwellings within the Parish of New Milton (additional to strategic site allocations, and existing commitments and small site windfall assumptions). The recently 'made' New Milton Neighbourhood Plan (July 2021), through Policy NM5, formally identifies sites sufficient to deliver at least 200 dwellings. These sites are set out in table 8 below.
Table 8: Sites identified in the New Milton Neighbourhood Plan
Site Reference | Site Name | Capacity |
|---|---|---|
NM5 (Area A) | Land south of New Milton Station, New Milton | 75 |
NM5 (Area B) | Land south of Manor Road, New Milton | 35 |
NM5 (Area C) | Land north of Osborne Road, New Milton | 20 |
NM5 (Area D) | Land at Station Road/Spencer Road, New Milton | 60 |
NM5 (Area E) | Land at Station Road/Elm Avenue, New Milton | 35 |
NM5 (Area F) | Land at Old Milton Road/Crossmead Avenue, New Milton | 30 |
Total | 255 | |
Small Site Windfall Allowance
2.13. The following paragraphs provide information on the estimated contribution to the Local Plan's housing supply arising from windfall development. The National Planning Policy Framework (NPPF) 2021 defines windfall sites as those which have not been specifically identified as available in the Local Plan process. Paragraph 71 of the NPPF advises that local 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 in the local area and will continue to provide a reliable source of supply. Local planning authorities also have the ability to include a windfall allowance for years 6-15 (using the same criteria as set out in Paragraph 67 of the NPPF).
2.14. Table 9 below shows historic delivery on small site windfalls (sites delivering between 1 and 9 dwellings) over the last 10 years. This analysis of housing completions indicates that an average of 83 dwellings per annum was delivered through small site windfall development. This indicates the consistently strong contribution small site windfall development makes to housing delivery in New Forest District Table 9: Small site completions since 2011/12
Table 9: Small site completions since 2011/12
Year | Completions on Small Site Windfalls |
|---|---|
2011/12 | 93 |
2012/13 | 61 |
2013/14 | 70 |
2014/15 | 77 |
2015/16 | 66 |
2016/17 | 85 |
2017/18 | 79 |
2018/19 | 76 |
2019/20 | 119 |
2020/21 | 100 |
2.15. In recent years, the Government has introduced a range of new permitted development rights that allow for greater flexibility of change of use. Permitted development rights now allow some commercial, office, light industrial, storage/distribution and agricultural premises to be converted to housing without the need for planning permission. Given this and past rates of delivery on small site windfalls, it is therefore clear that small site windfalls will continue to provide a reliable source of future supply.
2.16. Based on this analysis, the Council considers it entirely justifiable to include an allowance for small site windfalls (sites delivering between 1-9 dwellings) of 77 dwellings per annum. The small site windfall allowance was tested during the recent Local Plan examination and, in their Report on the Examination, the Inspectors examining the Local Plan concluded that the estimate of 77 completions per year on small windfall sites (less than ten dwellings) "is reasonable and realistic in light of past trends and given the potential for rural exceptions sites and schemes through permitted development rights".
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