Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10454

Received: 29/07/2022

Respondent: Mr Kulwinder Rai

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy DM5 Self-build and custom housebuilding - OBJECTION

There is a tension in the Council’s approach to Self-Build Custom Housebuilding in that most of those wishing to self-build dwellings want to do so in rural locations, areas that it wishes to restrict new housebuilding.

In the the Self-Build and Custom Housebuilding Topic Paper, Para 4.1 it is stated that:

‘When asked for more detail, rural locations are the most popular choice for those on the register. Only 5% of registrants (all on Part 1) would prefer a plot in Bedford or Kempston over other locations.’

It expands on this in Para 7.6.3 saying:

7.6.3. The Council’s evidence shows that greatest demand is for plots on sites in or around villages. Such sites tend to be smaller in size than those in and around the urban area, so a percentage policy that applied to sites over a threshold of 50 or 100 units would not yield the kind of self-build opportunity that the evidence shows is most in demand.

So what has the Council done in response to those findings? It has come up with a policy that secures a percentage of self-build plots on proposed, large estate-type developments, none of which are villages. In other words, exactly the sort of places where most self-builders have said they DO NOT want to be.

That is a wholly unsatisfactory solution to meeting the expressed needs of those interested in building their own dwellings and goes wholly against the spirit of the government’s support and encouragement for self-building in general.

Policy DM5 in the topic paper essentially says that large housebuilders will be released from their obligations to offer self-build plots if they have not been taken up after 12 months of marketing. Given that outcome, in my view, most large house builders will simply overprice such self-build sites in order to make them unattractive.

I would suggest changing the policy so that it makes clear that if the self-build sites remain unsold after 12 months of marketing that they be used for social and affordable housing, instead.

The other issue is how the Council is counting the number of self-builds that it is granted permission for in the past, and currently.

According to the Self-Build and Custom Housebuilding Topic Paper, paragraph 6.3 [Counting self-build] states:

‘The council has therefore taken a straight forward approach to what it considers suitable planning permissions and counts planning permissions for developments of a single dwelling in the borough towards its self-build and custom housebuilding requirement. Whilst these types of permissions are not explicitly submitted as self-build and custom housebuilding applications they provide potential opportunities for self-build due to the size of the development.’

By counting in this absurd manner the Council has arrived at the entirely predictable conclusion that it is meeting its statutory obligations in respect of self and custom building.That is very unlikely to be the case.

A much more accurate way of determining how many self-builds are being permissioned would, instead, to be to count the number of CIL exemptions actually granted for self-build.

This data is held by the Council but it chooses not to disclose it. One has to therefore assume that the actual number of confirmed self-build permissions granted, if that were the basis for calculation, would be much, much lower.

The current way Bedford Borough Council is counting how many self-build dwellings it has, and is, permissioning is fundamentally dishonest – it needs to base its figures expressly on the CIL self-build exemptions that have been granted, if its estimates are to be taken at all seriously.