Comment

Representation ID: 10532

Received: 26/07/2022

Respondent: Barton Willmore

Draft Policy DM5 (Self-Build and Custom-Build Housing) requires applications for new housing development to include plots for self-build and custom house builders, based on the overall number of net- additional dwellings proposed as below:
• 1-4 dwellings = no requirement
• 5-9 dwellings = 1 plot
• 10-29 dwellings = 2 plots
• 30-49 dwellings = 3 plots
• 50-69 dwellings = 5 plots
• 70-89 dwellings = 6 plots
• 90-100 dwellings = 7 plots
• 100+ dwellings = by negotiation
Draft Policy DM5 requires that for sites of 50 or more dwellings:
• “Plots will be marketed solely to individuals and associations on Part 1 of the Council’s Register in the first instance for an initial period of two months (minimum) from the commencement of the site being marketed. Following the initial marketing period, the offer of any unreserved plots will be extended to those on Part 2 of the Council’s Register and any new registrants to Part 1 having joined during the initial period. If the developer can provide evidence to the satisfaction of the Council that suitable purchasers from the Register have not been forthcoming within 6 months (minimum) of commencement of marketing the plots, they may be offered for unrestricted market sale to self-build and custom homebuilders including industry sector specialist companies,
• Any plots not reserved within a further 6 months (minimum) will be released from this specific policy requirement, following a total of 12 months of marketing.”
A self-build and custom housebuilding topic paper has been published as part of the evidence base to the BBLP 2040, which seeks to explain the background information about local demand for self-build and custom housebuilding, and therefore the reasoning for the policy. It sets out that whilst the self-build and custom housebuilding policy in the draft Local Plan 2030 was removed because the local plan Inspectors were concerned about the robustness of the Council’s register information on which it was based, a considerable amount of work has been done to ensure better quality local information is available for the BBLP 2040.
The rationale for such a policy is now considered to be the Council’s Self-build and Custom housebuilding Register (which is divided into two parts), and evidence prepared by Opinion Research Services (April 2021) demonstrating the level of demand for self-build and custom housebuilding plots in the Borough. In terms of the register, this has been split so that part 1 denotes a defined local connection, whilst part 2 are those eligible at the national level. As of October 2021, there were 90 individuals on the register, 46 with a local connection on part 1 and 44 on part 2. This has reduced considerably since March 2021, when there were 178 applicants were on the register, of whom 47 were on part 1 and the remaining 131 of part 2.
In addition, the evidence prepared by Opinion Research Services (April 2021) demonstrates that Bedford Borough Council is currently providing sufficient single dwelling plots to comply with its requirement to meet the needs of those on Part 1 of its own self-build and custom housebuilding register. This has been achieved without any designated policy requirement and is also based purely on the number of planning applications that were granted planning permission for developments of a single dwelling in the Borough. The report therefore considers that it is likely that at least some properties on sites with more than one dwelling will also fall within the definition of being self-build and custom housebuilding and as such a greater number of plots will realistically have been provided.
Based on the above, it is unclear why specific requirements are included within the draft policy, and why these are so high. There is not a necessity within National policy to include self and custom build thresholds, with the PPG (Paragraph 025 Reference ID: 57-025-201760728) setting out a number of ways in which Local Authorities can support self and custom build. As such the currently proposed BBLP40 approach is unnecessary in the context of the tests of soundness set out within paragraph 35 of the NPPF which require plans to be consistent with national policy.
In addition, the evidence provided indicates that a draft Policy which continues to encourage self-build and custom build developments, where appropriate (in line with the NPPF paragraph 62) would be sufficient. We would welcome a policy which allows consideration of the level of demand for self-build and custom housing and a requirement for a proportionate level of self-build and custom plots at the time a planning application is submitted.
Whilst we welcome a clause in the Section 106 Agreement, for the release of a plot from the requirement of Policy DM5 after a period of marketing, we consider a 12-month minimum marketing period to be unreasonable and unjustified. It is also considered that the wording of the policy should be revised in order to specify that the requirements will not apply to flatted developments.