Object

Representation ID: 7899

Received: 24/09/2021

Respondent: Home Builders Federation

he HBF is concerned with the statement in paragraph 3.28 that the Council will not allocate small sites simply to satisfy the requirement set out in paragraph 68 of the NPPF that 10% of all homes should come forward on small sites that are either allocated in the local plan or identified in the brownfield register. The Council argue that this it is not necessary to apply national policy as the there is a consistent supply of such sites coming through as windfall. This position completely misunderstands the reasons for allocating small sites rather than rely wholly on these to be brought forward as windfall sites.
13. The Government has been keen to support small and medium (SME) sized housebuilders deliver more new homes across the country. Up until the 1980s, small developers once accounted for the construction of half of all homes built in this country resulting in greater variety of product, more competition, and faster build-out rates. Since then, the number of small companies has fallen by 80% following the introduction of the plan-led system in 1990.
14. The HBF has undertaken extensive consultation with its small developer members and one of the chief obstacles for small developers is that funding is extremely difficult to secure without a full, detailed, and implementable planning permission. Securing an implementable planning permission is extremely difficult if small sites are not allocated. Without implementable consents lenders are uneasy about making finance available or else the repayment fees and interest rates they set will be very high. Small developers, consequently, need to invest a lot of money and time up-front in the risky business of trying to secure an allocation and a planning permission, and this is money that many small developers do not have and can be a barrier to entry for new housebuilders.
15. If the Council are to ensure there is a wide variety of SME house builders operating in its administrative area, and the benefits it brings to the speed of delivery and variety of homes, it must ensure that there is a variety of sites. This is why the Government, through the NPPF, now requires local authorities to allocate sites of varying sizes. The fact that such sites currently come through from windfall is therefore not a justification for this proposed inconsistency with national policy.