Support

Representation ID: 6479

Received: 13/09/2021

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

1. 2. 3. 4. 5. 6. 7. 8. The number of self-build plots required through Policy SB1 relative to the number of dwellings at a given site is too high relative to the evidence of demand demonstrated through the evidence base, particularly in the case of the explicit and anticipated requirements suggested for larger developments, particularly the evidence base leaves a large degree of uncertainty about demand. The ‘Self-build and Custom Housebuilding Guidance’ states in paragraph 11 that “Local planning authorities should use the demand data from the registers in their area, supported as necessary by additional data from secondary sources (as outlined in the housing and economic development needs guidance), to understand and consider future need for this type of housing in their area”. The “Bedford Borough Local Housing Needs Assessment Self-build and Custom Housebuilding Report of Findings April 2021” document within the evidence base states that “the current assumed supply of self-build and custom housebuilding is currently measured only by those properties with permission for a single dwelling. In practice 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.” Therefore by its own admission, the evidence base document is of limited accuracy in terms of the demand for self-build plots and the number of plots available. Measuring need in this way does not take into account how many permissions for single dwellings have been built out and it is also unclear “how many households from the register have been able to access these plots because the information is not recorded”. Furthermore, paragraph 1.20 of the same evidence base document also states 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 for either allocated sites for serviced plots, or a requirement for a proportion of plots on larger sites to be made available”. This draws into question the justification for Policy SB1 being so specific in stating plot numbers relative to the size of a given scheme when sufficient provision is already being achieved without such a policy. The requirements are relatively high when compared to the size of the developments specified. For example, a requirement of 2 self and custom build plots on a 10 dwelling sites equates to 20% provision, and a requirement of 7 self and custom build plots on a 90 dwelling site equates approximately to 8% provision. This when typically many local plans require roughly 5% provision or are negotiated on a case by case basis based on evidence of need. This also represents an unbalance in how much provision is sought based on the scale of a site, when there is no evidence to support such an approach. Furthermore, there is a fundamental question as to whether the provision of self-build plots on all allocations actually meets the desires and aspirations of self-builders, who often want to deliver a house on a standalone plot or with increased external space, which would not be available when delivered as part of a large site. In addition, there are issues in terms of phasing, delivery and health and safety implications from such an approach. Therefore, given the commentary provided through the evidence base and the admitted need for more information to be gathered, we consider that a Policy in the form of SB1, requiring specific numbers of plots to be self-build on developments of various scales, is not justified by the evidence base. Such an unjustified approach may lead to unnecessary delays and uncertainty to the delivery of dwellings across the district in potentially requiring relatively large proportions of self and custom build plots which may not be taken up as such. It is therefore suggested that the policy be amended to make an allowance for small exception sites to be delivered on land adjacent to settlement boundaries, which has been done successfully in other Districts, such as South Northamptonshire (as was, now West Northamptonshire). If there is to be an allowance on large sites in addition to the above then we would suggest that this is set at up to 3% 10 provision to be negotiated on a case by case basis if there is a lower level of need identified. This will help to facilitate the speedy delivery of new dwellings across the borough and accounts for the identified need for the evidence base to be further developed. 9. Additional point for Policy SB1: “Proposals for single self or custom build sites immediately adjoining the confines of settlements will normally be permitted where they help to meet demand as demonstrated by Part 1 of the council’s Self and Custom Housebuilding Register and are compliant with other policies of this plan.” 10. Revised wording to Point ‘I’ of Policy SB1 is suggested below: “The Council will require applications for new housing development to make up to 5% of the plots available on site as serviced self or custom build plots, subject to negotiation based on evidence of identified local need.”