The explanatory text para 160 states (below) that the policy supports small brownfield sites as windfall that are not necessarily sites in or adjacent villages.

Windfall developments
160. Windfall developments provide additional potential for housing delivery not counted in the above table. The policy supports appropriate windfall development, including sites in and adjacent to villages and small brownfield sites. Based on previous local trends, the likely scale of windfall development is in the region of 3,870 dwellings between 2018 and 2038. Demand will determine whether windfall development is instead of, or in addition to, allocated growth.

Agree that appropriate windfall development should be allowed for to deliver housing and that small brownfield sites should also be considered appropriate subject to site specific matters. There is a clear national drive for the re-use of brownfield sites. However Policy 1 as currently drafted does not clearly allow for this.
H1 sets out windfalls are acceptable as follows
• Within settlement boundaries in accordance with the above settlement hierarchy;
• Elsewhere in village clusters, subject to the requirements of policy 7.4.
• On sites of up to 3 dwellings in all parishes, subject to the requirements of policy 7.5.
A further bullet point should be added to refer to small brownfield sites – which could be outside of settlements. It would also be helpful to have some understanding of ‘small’.

As currently drafted, there is a risk that suitable brownfield sites of a decent size, such as site GMLP0454, which is capable of providing approx 34 houses falls between the thresholds of not being allocated in this Plan and not meeting the Policy as currently drafted, which would not be in the interests of prioritising the use of brownfield land over greenfield. It is requested that GMLP0454 is reconsidered for allocation as part of this Plan.