Object

Representation ID: 6573

Received: 13/09/2021

Respondent: Clarendon Land and Development Ltd

Agent: Fisher German LLP

Self-build and custom housebuilding
2.32 The approach adopted by the Council in respect of Policy SB1 - Self-build and custom housebuilding
with how the Council has interpreted other evidence and how such evidence has informed other policies
within the Plan. The Council has published evidence on the topic in the document the Bedford Borough
Local Housing Needs Assessment Self-build and Custom Housebuilding (April 2021). This document
concludes that the desires of self-builders is to build large, expensive properties and that currently
sufficient single dwelling permissions adequately caters for this need. This accords with our
understanding of self-build, wherein people are seeking bespoke and unique opportunities, not simply
adjacent to a modern housing development.
2.33 Despite this, and for no justified reason, the Council have opted to seek to promote a policy which
requires serviced plots to be delivered on the majority of new housing sites. This approach is not
effective, consistent with evidence and as such is not supported nor considered sound. It is not clear
what the housing target is for self or custom build, and how this has informed the policy, particularly
having regard for the conclusions of the evidence document which demonstrates that there are
sufficient units being delivered.
2.34 It is well established that such criteria are difficult to deliver on modern housing developments and do
not serve to provide additional units. In reality, such requirements may impede development
unnecessarily, adding to developer burden with little merit. Such proposals can create enclaves within
or adjacent to housing schemes, with designs which may be entirely at odds with the aesthetic of the
rest of the scheme, which will have been specifically designed as a collective whole. In our experience,
self-builders generally do not want to buy serviced plots within or adjacent to a modern housing estate.
Our experience is that for the most part that they are instead looking for more bespoke rural
opportunities.
2.35 We are yet to see evidence that this method of delivery has been successful. Furthermore, just because
individuals are registered on the self-build register it does not mean that they will all build their own
property, even if suitable land was available. The reality is the difficulty and skills required will mean only
a small percentage of those on the register will ever develop a self-build property. It is also important to
note that individuals can be on multiple self-build registers, even with a local connection test, which
inflates the figures across a number of areas. Unless demand for plots is means tested, with expressions
of interest supported by evidence of finances to build such a house, to simply just deliver self-build plots on strategic sites is an arbitrary approach which lacks nuance and will harm more justified housing
delivery.
2.36 This policy requirement will serve to frustrate and slow housing delivery, given special consideration
would need to be given to the location of the plots and how they can be accessed safely and
independently from the typical development parcels. The delivery of plots following unsuccessful
marketing is also more complex than suggested within the policy. The Policy assumes such plots could
simply just be built out by the developer; the nature of the plots may not however lend themselves to
being built by the developer and as such could leave undeveloped plots for significant period of time.
Such requirements will also deter developers, given the increased complexity and lack of certainty of
outcomes. Custom build may not be in the business model of some housebuilders, which may preclude
them from bidding for sites if such a requirement is retained. Self and Custom build is a market choice
and should be led by the free market, it is not and should not be treated as a need to be satisfied in the
same manner as affordable housing. If there is sufficient demand for such units, and people are willing
to pay a premium, then it will be adopted by more housebuilders.
2.37 The Council should instead seek to ensure the continuation of a positive policy environment where
suitable self-build schemes, either of individual units or larger schemes or specific schemes providing
serviced plots will be treated favourably. This encourages delivery in line with the Council's statutory duties, without compromising sites which make up a vital facet of the Council's overall proposed housing supply. It will also more likely better serve the self-build market by enabling development in line with the
wishes of perspective self-builders. Having regard for the evidence, this policy is not sound, as it is not
effective nor justified.
2.38 It is noted that Council's evidence as suggested that sufficient small-scale windfall housing sites are
expected to come forward to negate the need for a specific policy or allocations to guarantee the 10%
small sites requirement. This is a very similar position to self-build/custom-build, where the evidence
suggests there is not a need for a policy intervention and as such none is suggested. This is entirely at
odds with the self/custom build policy, which again is clearly not necessary, but the approach adopted
is entirely different. The Council should be guided by its evidence and remove this policy requirement.