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Representations on VALP Proposed Submission - 3.83
OBJECT Chiltern Area of Outstanding Natural Beauty Conservation Board (Dr Lucy Murfett)
It is unclear why windfalls are only being counted for small sites (4 or fewer) when the NPPF para 48 and NPPG para 24 makes no restriction that windfalls cannot be large sites too. The 962 windfall allowance for the plan period is a low estimate given permitted development changes in the GPDO 2015, the introduction of automatic planning permission for some brownfield sites in the Government pilot scheme and the digital revolution changing how we work and shop, freeing up buildings and land. Far more brownfield land and building conversions may emerge for residential reuse.